-Demolition Hazardous Material Administration Building ...

Pre-Demolition Hazardous Material Survey Report Administration Building, Building D

Piedmont High School 800 Magnolia Street

Piedmont, CA

May 28, 2018 (Final) Milani & Associates Project No.: 1048

Submitted to: Piedmont Unified School District

760 Magnolia Street Piedmont, CA 94611

Submitted by: Milani & Associates

2655 Stanwell Drive, Ste. 105 Concord, CA 94520

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EXECUTIVE SUMMARY

Piedmont Unified School District (PUSD) intends to demolish the existing Administration Building (Building D), trellis/portico structure and associated concrete walkways and surface treatments in the immediate vicinity of the Administration Building. The Administration Building is part of the Piedmont High School Campus operated by PUSD and is located at 800 Magnolia Avenue in Piedmont, CA. The Administration Building and the Piedmont High School Campus are shown in the Vicinity Map, Figure 1. The approximate demolition limits of the project are shown in Figure 2. The demolition of the Administration Building will be subject to removal of hazardous materials covered under the federal NESHAP Regulation. To comply with NESHAP, a demolition-level hazardous material survey was conducted by Milani & Associates under contract to the PUSD. The pre-demolition hazardous materials survey included the following elements:

• Review of previous AHERA Triannual Re-Inspection Reports (1988, 1991 and 1994),

• Review of the AHERA Management Plan (1988),

• Review of the previous fire alarm hazardous material survey for the Piedmont High School,

• Review of previous waste characterization testing associated with the selected Administration Building renovation projects.

• Inspecting and sampling the structure (interior, exterior and roof) for Regulated Asbestos Containing Material (RACM) for compliance with the federal NESHAP regulation and applicable federal and state Occupational Safety and Health Administration (OSHA) regulations,

• Evaluating and sampling the structure (interior, exterior, roof and concrete foundation) for Category I Non-Friable (CAT I NF) and Category II Non-friable (CAT II NF) Asbestos Containing Materials (ACMs). The evaluation included assessing if these materials could be made friable during the demolition of the building. Where these materials could be made friable during demolition, these materials would be re-classified as RACM and would be subject to the federal NESHAP regulation, applicable federal and state Occupational Safety and Health Administration (OSHA) regulations, and Bay Area Air Quality Management District (BAAQMD) regulations covering building renovation and/or demolition,

• Evaluating and sampling building materials, building components and paint coating systems for lead using bulk sampling and nondestructive X-ray fluorescence (XRF) testing for initial waste characterization purposes, and

• Inspecting the structure for the presence of Other Regulated Materials (ORMs) and Universal Wastes that may require removal prior to demolition, may require special handling and packaging or may require waste profiling to determine appropriate disposal.

Previous asbestos and lead data from prior hazardous material surveys and waste characterization were utilized as reported. The scope of the pre-demolition survey did not include performing a mold survey,

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sampling of sub-slab vapor barrier systems or sampling of the underground utilities (electrical, water, sewer) for asbestos. The scope of the pre-demolition survey did not include collection and analysis full depth samples of add-on texture coats with lead-containing or lead-based paint coating systems for waste characterization. The hazardous material survey also excluded testing soil for Naturally Occurring Asbestos (NOA). Soil testing for NOA was performed by the project geotechnical consultant. HAZARDOUS MATERIAL SURVEY SUMMARY Renovation History Based on a review of the AHERA management report, the Administration Building was originally constructed in 1978. PUSD personnel indicated that in the 1990’s, Classroom 18 was converted for use as counseling offices. The Classroom 18 counseling office conversion included installation of new partition walls, carpet, drop ceiling system, new HVAC ducting and new lighting. The original lighting system for Classroom 18, which is located above the new drop ceiling, was disconnected but not removed. Hazardous Material Survey Overview A pre-demolition hazardous material survey was conducted on July 13, 2017. A supplemental survey was conducted on May 10, 2018. Reasonable efforts were made to access all areas and locate conditions/materials representative of the structure. The general site access was made available by PUSD. Survey activities were performed by Mr. Mark Milani, Cal/OSHA Certified Asbestos Consultant 08-4469 and CDPH Certified Lead Inspector/Assessor #21323 and Mr. Jerry Lee, Environmental Technician with Milani & Associates. A preliminary walk-through of the interior, exterior and roof of the structure was performed to familiarize the inspector with the structure. During the walk-through, heating, ventilation and air conditioning (HVAC) ducting; hot and cold water supply piping; other mechanical systems requiring thermal system insulation (TSI); and other suspect applications that were readily accessible were inspected for suspect asbestos-containing TSI, where present. The interior, exterior and roof of the building were assessed for suspect asbestos-containing surfacing materials, suspect asbestos-containing miscellaneous friable materials, suspect asbestos-containing CAT I NF materials, and suspect asbestos-containing CAT II NF materials. The interior, exterior and roof of the building were also assessed for the following:

• Suspect lead-containing components,

• Suspect lead-containing paint (LCP) coating systems,

• Suspect lead-based paint (LBP) coating systems,

• Other Regulated Materials (ORMs) and

• Universal Wastes. The assessment for lead-containing components, LCP and LBP included bulk sampling of ceramic tile building components and conducting a non-destructive X-ray fluorescence (XRF) lead survey of the

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interior, exterior and roof of the structure. The XRF survey was used to analyze painted surfaces and architectural components for lead presence.

The following ORMs and Universal Wastes were assessed using visual observation methods:

• Mercury-containing devices (fluorescent light tubes, compact fluorescent bulbs [CFLs], HVAC thermostats),

• PCB-containing devices and/or materials (electrical light ballasts, caulking),

• Low-Level Radioactive Materials (self-powered [tritium-containing] exit signs),

• Ozone Depleting Chemicals (compressor oils and refrigerants used in HVAC and refrigeration systems), and

• Pressure Treated Wood/Treated Wood Waste (TWW). ORMs, Universal Wastes, and other known hazardous materials are also generally required to be removed prior to demolition since they can require special handling, packaging, and recordkeeping for disposal and/or recycling. Pressure treated wood is required to be handled and disposed of under the alternative management standards (AMS) under California Code of Regulations, Title 22, Division 4.5, Chapter 34 where it is not scheduled for reuse or reclamation by the owner. Sampling Summary (Asbestos) Bulk sampling for asbestos was conducted in accordance with modified procedures outlined in the Asbestos Hazard Emergency Response Act (40 CFR 763.86, Sampling). The procedure requires the inspector to select random sampling locations from homogeneous materials suspected to contain asbestos. To comply with recent EPA and BAAQMD guidance, the supplemental ACM survey also included evaluating and sampling the concrete foundation systems (footings and slab-on-grade), and concrete surface treatments that were scheduled for demolition for asbestos. Fifty-six (56) suspect ACM bulk samples were collected from the interior and exterior of the building and from the building roof and foundation systems during the survey. The samples were sealed in uniquely labeled bags and shipped under chain-of-custody procedures to EMSL Analytical Laboratories (EMSL) located in San Leandro, CA. EMSL is accredited by the National Institute of Standards and Technology’s National Voluntary Laboratory Accreditation Program (NVLAP) for the analysis of asbestos in bulk samples by EPA Method 600/R-93/116. A copy of EMSL’s NVLAP Certification is included in Appendix A. Asbestos analyses included analysis by standard PLM. This was augmented by point counting (400-point count) on selected bulk samples where samples were identified as containing trace asbestos (Trace [<1% asbestos]). In addition, all drywall joint compound layers found to contain asbestos at less than 3% asbestos were also subject to 400-point count. The asbestos bulk sample locations for the building interior, building exterior, building foundation and roof are shown on the Bulk Sample Location Plans, Figures 3 and 4. The results of the asbestos analyses are tabulated in Tables 1A (interior and foundation), 1B (exterior & roof), and 1C (site exterior). The asbestos analytical reports are included in Appendix A. The referenced Tables and Figures are included in the respective tabbed “Figures” and “Tables” sections of the report.

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Sampling Summary (Lead) The assessment for lead-containing components, LCP and LBP included bulk sampling of ceramic tile building components and conducting a non-destructive X-ray fluorescence (XRF) lead survey of the interior, exterior and roof of the structure. The XRF survey was used to analyze painted surfaces and architectural components for lead presence. Four (4) bulk samples were collected from the ceramic tile systems observed in the two exterior restrooms. The lead bulk samples were sealed in uniquely labeled bags and shipped under chain-of-custody procedures to EMSL Analytical Laboratories (EMSL) located in San Leandro, CA. EMSL is certified by the California Department of Health Services Environmental Laboratory Accreditation Program (ELAP) for the various EPA and SW-846 Test Methods utilized for lead testing. A copy of EMSL’s California ELAP Certification is included in Appendix A. Bulk sampling for lead, where performed, was performed in accordance with industry standards in existence at the time of the project. The XRF survey was performed in accordance with industry standards in existence the time of the project. Sample locations were determined based on the building components and paint coating systems observed during the inspection. The bulk lead sample locations for the building interior and exterior are shown on the Bulk Sample Location Plan, Figures 3 and 4. The location of building components and paint coating systems identified as being LCP or LBP determined during the XRF survey are shown in Figure 5. The results of the bulk lead analyses are tabulated in Tables 2A and 2B. Figure 6 depicts a lead waste characterization flowchart. Copies of the lead analytical reports are included in Appendix A. Copies of the lead XRF survey reports are included in Appendix B. Sampling Summary (Previous Survey Data) Previous asbestos and lead data from prior hazardous material surveys and waste characterization were utilized as reported. The previous asbestos and lead bulk sample results have been incorporated into the Asbestos Bulk Sample Analytical Summary Tables (Tables 1A, 1B, and 1C) and into the Lead Bulk Sample Analytical Summary Tables (Tables 2A and 2B), respectively. HAZARDOUS MATERIAL SURVEY FINDINGS - ASBESTOS Survey Areas Found to Contain Asbestos The summarized inventory of materials tested and found TO CONTAIN asbestos at concentrations greater than 1% that are regulated under AHERA as TSI, Surfacing and Miscellaneous and regulated under NESHAPS as CAT I NF, CAT II NF or RACM are described below: Building Interior:

• Resilient Floor Tile (RFT), gray-brown with black mastic, 5% Chrysotile [Miscellaneous/Category I NF ACM]. The RFT is in the Janitor Closet (entire floor) and the North Storeroom (approximate 80% of floor area),

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• Sink Soundproof Coating, black, 3% Chrysotile [Miscellaneous/Category I NF ACM]. The sink is in the Work Room in the administration section of the building.

Building Exterior and Roof:

• None Identified Site Exterior and Concrete Foundation:

• None Identified The summarized inventory of materials tested and found TO CONTAIN asbestos at concentrations regulated under OSHA (greater than 0% but less than or equal to 1%) is described below: Building Interior:

• Drywall Joint Compound, <0.25% to 0.5% Chrysotile (ACCM), by PLM 400-point count

• Blackboard Shim Tile, <25% Chrysotile (ACCM), by PLM 400-point count

The ACCM drywall is located throughout the building interior except in the counseling office renovation area (former Classroom 18). The shim tile is located behind the original blackboards in all classrooms. Building Exterior and Roof:


• None Identified Survey Areas Not Sampled but Assumed to Contain Asbestos

Based on the results of the visual inspection, the summarized inventory of materials that are SUSPECT AND/OR ASSUMED TO CONTAIN asbestos is described below: Building Interior:

• Interior fire-rated doors through-out the building. Building Exterior and Roof:

• Exterior fire-rated entrance doors on the south side of the building.

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Site Exterior and Concrete Foundation:

• Vapor barrier under the concrete slab on grade floor (where present) Survey Areas Found Not to Contain Asbestos

Building Materials: The summarized inventory of building materials tested and found NOT TO CONTAIN asbestos are detailed in Section 3.4 of the report. Site Soils: The hazardous material survey excluded testing soil for Naturally Occurring Asbestos (NOA). Soil testing for NOA was performed by the project geotechnical consultant, Geo-Engineering Solutions, Inc. Based on a review of NOA soil testing results provided by the project geotechnical consultant, NOA was not detected in the surficial soils and bedrock expected to be disturbed during construction of the new building at the project site. HAZARDOUS MATERIAL SURVEY FINDINGS - LEAD Lead Survey Findings – Lead-Based Paint/Building Components The following is a list of building components and/or paint coating systems that were found to contain lead at or above the federal standard for lead-based paint (5,000 ppm or 0.5% by weight, or ≥1.0 mg/cm2). All homogeneous components located throughout the building shall be assumed as having similar concentrations: Interior:

• White Pebble Texture Coat (1.0 mg/cm2) – Interior column faces on all sixteen (16) columns located along exterior walls of the building.

Exterior:

• White Pebble Texture Coat (1.0 mg/cm2) – Exterior faces of columns on the north side (six columns) and east side (four columns) of the building.

• White Stucco Texture Coat (1.0 mg/cm2) – East-side building wall face.

• Lead Sheet Pipe Flashing (99% inorganic lead) - At all five (5) roof vent pipe locations. Lead concentrations reported above in ppm or percent by weight were determined by bulk sample analysis. Lead concentrations reported in mg/cm2 were determined by XRF. The XRF survey report is included in Appendix B. Note: Based on the XRF survey results, the lead-based white pebble texture coat was only found on the exterior columns on the east and north side of the Administration Building. The exterior building columns on the south and west side of Administration Building and the columns that support the Trellis/Portico structure have a lead-containing white pebble texture coat.

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Lead Survey Findings – Lead-Containing Paint/Building Components The following is a list of building components and paint coating systems that were found to contain lead at concentrations below the federal standard for LBP (<5000 ppm, or 0.5% by weight or less than 1.0 mg/cm2). Building components and paint coating system with lead concentrations below the federal standard for LBP are considered Lead-Containing Materials and are regulated by both Cal/OSHA and EPA. All homogeneous components shall be assumed to contain similar concentrations: Interior:

• Wall and Ceiling Paint Coating Systems (various colors - <100 ppm) - All painted wall and hard ceiling systems located in the interior of the building.

• Wood Trim, Door, and Door Casing Paint Coating Systems (various colors - 0 mg/cm2) - All painted wood wall trim, wood doors and wood door casings located in the interior of the building.

• Metal Lockers and Metal Door Systems (various colors - 0 mg/cm2) - All painted metal lockers (hallways), metal doors and metal door frames in the interior of the building.

• Ceramic Tile Wall Systems (0.58 mg/Kg) – Green ceramic tile in exterior accessed restrooms

• Ceramic Tile Floor Systems (7.3 mg/Kg) – Brown ceramic tile in exterior accessed restrooms Exterior:

• White Stucco Texture Coat (0.2 – 0.7 mg/cm2) – North, South, and West side building wall faces.

• White Pebble Texture Coat (0.2 – 0.5 mg/cm2) – Exterior faces of columns on the south side (six columns) and west side (four columns) of the building and all exterior columns that support the wood Trellis/Portico structure (thirteen columns).

• White/Beige Wood Window Casing (0 mg/cm2) – All painted wood surround casing on the exterior of the building.

• Metal Windows and Doors (various colors - 0 mg/cm2) – All painted metal windows, metal doors and metal door frames on the exterior of the building.

Lead concentrations reported above in ppm or percent by weight were determined by bulk sample analysis. Lead concentrations reported in mg/cm2 were determined by XRF. The XRF survey report is included in Appendix B. See Table 2A for results of paint chip analyses. The results of the XRF survey are included in Appendix B.

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Note: Should construction finishes with “detectable” concentrations of lead be disturbed, OSHA compliance measures and waste characterization measures for all lead-containing waste streams will be required. Lead Waste Stream Identification and Preliminary Waste Characterization Assessment Demolition Waste Stream Identification: As part of the lead survey, a demolition waste stream assessment was performed based on the lead-based and lead-containing building components and/or paint coating systems that were identified. Based on a review of the bulk sample and XRF data, the following waste streams were identified that will be generated during the demolition of the building have the potential to contain lead: Interior:

• White Pebble Texture Coat (0. 4 to 1.0 mg/cm2) – Interior column faces of all sixteen (16) columns located along exterior walls of the building.

• Wall and Ceiling Paint Coating Systems (various colors - <100 ppm) - All painted wall and hard ceiling systems located in the interior of the building.

• Wood Trim, Door, and Door Casing Paint Coating Systems (various colors - 0 mg/cm2) - All painted wood wall trim, wood doors and wood door casings located in the interior of the building.

• Metal Lockers and Metal Door Systems (various colors - 0 mg/cm2) - All painted metal lockers (hallways), metal doors and metal door frames in the interior of the building.

• Ceramic Tile Wall Systems (0.58 mg/Kg) – Green ceramic tile in exterior accessed restrooms

• Ceramic Tile Floor Systems (7.3 mg/Kg) – Brown ceramic tile in exterior accessed restrooms Exterior:


• White Stucco Texture Coat (1.0 mg/cm2) – East side building wall face.

• Lead Sheet Pipe Flashing (99% inorganic lead) - At all five (5) roof vent pipe locations.


• White Pebble Texture Coat (0.2 – 0.5 mg/cm2) – Exterior faces of columns on south side (six columns) and west side (four columns) of the building and all exterior columns that support the wood Trellis/Portico structure (thirteen columns).

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• White/Beige Wood Window Casing (0 mg/cm2) - All painted wood surround casing on the exterior of the building.

• Metal Windows and Doors (various colors - 0 mg/cm2) -- All painted metal windows, metal doors and metal door frames on the exterior of the building.

Preliminary Waste Characterization Assessment – Waste Streams Not Requiring Additional Characterization: The following waste streams were determined not to require additional waste characterization based on the XRF and bulk lead sample data obtained during the survey: Interior:

• Wall and Ceiling Paint Coating Systems (various colors - <100 ppm) on drywall substrate - All painted wall and hard ceiling systems located in the interior of the building.

• Wood Trim, Door, and Door Casing Paint Coating Systems (various colors - 0 mg/cm2) on a wood substrate - All painted wood wall trim, wood doors and wood door casings located in the interior of the building.

• Metal Lockers and Metal Door Systems (various colors - 0 mg/cm2) on a metal substrate - All painted metal lockers (hallways), metal doors and metal door frames in the interior of the building.

• Ceramic Tile Wall Systems (0.58 mg/Kg) on mortar bed substrate – Green ceramic tile in exterior accessed restrooms

• Ceramic Tile Floor Systems (7.3 mg/Kg) on mortar bed substrate – Brown ceramic tile in exterior accessed restrooms

Exterior:

• White/Beige Wood Window Casing (0 mg/cm2) over concrete substrate – All painted wood surround casing on the exterior of the building.

• Metal Windows and Doors (various colors - 0 mg/cm2) over concrete substrate – All painted metal windows, metal doors and metal door frames on the exterior of the building.

• Lead Sheet Pipe Flashing (99% inorganic lead) on metal substrate – At all five (5) roof vent pipe locations

Preliminary Waste Characterization Assessment – Waste Streams Requiring Additional Characterization: The following waste streams were determined to require additional waste characterization based on the XRF and bulk lead sample data obtained during the survey:

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• Waste Stream #1: White Pebble Texture Coat (0.4 to 1.0 mg/cm2) over concrete substrate – Interior column faces of all sixteen (16) columns located along exterior walls of the building.

• Waste Stream #2: White Pebble Texture Coat (0.2 to 1.0 mg/cm2) over concrete substrate – Exterior faces of columns on the building (sixteen columns) and all exterior columns that support the wood Trellis/Portico structure (thirteen columns).

• Waste Stream #3: White Stucco Texture Coat (0.2 to 1.0 mg/cm2) over concrete substrate – on exterior building wall faces.

The demolition waste streams identified above will need to be tested for total lead (TTLC) and soluble lead (WET and TCLP) to determine if the components will need to be disposed of as Construction Debris, Non-RCRA California Regulated HW - Lead or RCRA Hazardous Waste – lead. The specific method of sampling will depend on if the concrete will be recycled or if it will be disposed of to a Class II/III landfill. The specific sampling methods include the following: Method #1 – Concrete is Recycled: Based on discussion with local concrete recyclers, concrete to be recycled must be free of all paint coating systems that contain lead. This will require removal of the paint coating systems from the following building components and/or waste stream:

• Waste Stream #1: Building Columns (interior column faces) – There are sixteen (16) columns located around the perimeter of the building. The interior faces of these columns contain a white pebble texture coat containing lead between 0.4 and 1.0 mg/cm2. The texture coat is applied to interior surfaces of the concrete columns for the full interior room height.

• Waste Stream #2: Building Columns (exterior faces) and Trellis/Portico Structure Columns: The exterior faces of all the building columns and the columns that support the trellis/portico structure were observed to have a white pebble texture coat containing lead between 0.5 and 1.0 mg/cm2. The texture coat is applied to the full height of the columns.

• Waste Stream #3: Exterior Building Walls: The faces of all exterior walls were observed to have a white texture stucco coat containing lead between 0.2 and 1.0 mg/cm2. The texture stucco coat is located on all exterior wall faces of building exterior.

The individual waste streams will need to be kept separate for waste characterization purposes. Representative bulk samples from each waste stream will need to be collected. The sampling of each waste stream should follow procedures detailed in EPA SW-846. This will require collecting between three and six representative samples. Samples should be analyzed for total lead and soluble lead as shown in Figure 6. Method #2 – Concrete is Not Recycled: Where painted concrete will not be recycled, the demolition contractor will need to determine if additional waste characterization will be necessary to establish a waste profile for the concrete scheduled for disposal. Where determined to be necessary, representative samples will need to be collected. This would require collecting full-depth samples using concrete coring methods.

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HAZARDOUS MATERIAL SURVEY FINDINGS - ORMS AND UNIVERSAL WASTES LEAD Survey Findings – ORMs and Universal Wastes The following ORMs and/or Universal Wastes were observed during the survey or are suspected to be present based on field observation. Quantity estimates for the ORMs and Universal Wastes identified below are presented in Tables 3 and 4:

• Mercury-containing Devices The following mercury-containing devices were observed or are believed to be present:

1. Fluorescent Lighting Fixtures (Tube) – The interior of the building contains multiple ceiling-mounted tube-style fluorescent light fixtures. A total of two hundred forty-eight (248) fluorescent light fixtures are estimated to be present in the building. For demolition purposes, each light fixture is assumed to contain two to four fluorescent light tubes.

2. Fluorescent Lighting Fixtures (CFL) – While not observed during the survey, the interior of the building may contain ceiling-mounted light fixtures that contain compact fluorescent bulbs (CFLs). For demolition purposes, where present, CFL containing light fixtures are assumed to contain up to two CFLs.

3. Mercury-containing Thermostats – While not observed during the survey, up to four (4)

mercury-containing thermostats are believed to be present. There is believed to be one (1) thermostat for each HVAC unit.

• PCB-containing Device and Materials

The following PCB-containing devices were observed or are believed to be present: 1. Fluorescent lighting fixtures – A total of two hundred forty-eight (248) fluorescent

light fixtures were observed. The fluorescent light fixtures are assumed to contain one ballast, which may contain PCBs. The ballasts were not readily accessible during the survey because they were internally mounted. Internally mounted ballasts that were not able to be observed should be considered to contain PCB’s until removed from the light fixture and verified to be non-PCB containing. The total quantity of ballasts was estimated to be two hundred forty-eight (248) based on the observed quantity of fluorescent light fixtures.

• Low-Level Radioactive Materials (tritium containing exit signs and smoke detectors)

The following Low-Level Radioactive Materials containing components were observed or are believed to be present:

1. Exit Signs – The building was observed not to contain exit signs.

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2. Smoke Detectors – The building was observed to contain numerous smoke detectors.

The devices are in hallways, office, and classrooms. The locations of smoke detectors are shown on the fire alarm drawing for the building. A copy of the fire alarm drawing is included in Appendix C.

• Ozone Depleting Chemicals (compressor oils and refrigerants) The following components containing ozone-depleting chemicals were observed or are believed to be present:

1. HVAC System – The building is equipped with four (4) roof-mounted air conditioning

units. The interior of these units could not be accessed. Each unit should be assumed to contain compressor oil and refrigerant.

• Electronic Wastes The following components that would be classified as electronic wastes that were observed or are believed to be present include the following:

1. Digital Thermostats –– While not observed during the survey, up to four (4) thermostats

are believed to be present. There is believed to be one (1) thermostat for each HVAC unit.

2. Digital/Electronic Heat Detectors - The building was observed to contain numerous heat detectors. These devices are in hallways, office, and classrooms. The locations of the heat detectors are shown on the fire alarm drawing for the building. A copy of the fire alarm drawing is included in Appendix B.

3. Other Electronic Wastes – If other electronic wastes are found, they shall be disposed and/or recycled in conformance with applicable regulations.

The PUSD may require that fire alarm components, including the Fire Alarm Control Plan (FACP), smoke detectors, heat detectors and other components to be salvaged and returned to PUSD.

• Treated Wood Waste

Portions of the existing Trellis/Portico structure and wood trellis sunshade are constructed using pressure treated wood. The Trellis/Portico structure and wood trellis sun shades are scheduled for demolition. The pressure treated wood waste stream generated from this demolition would be considered treated wood waste (TWW). Base on the visual survey and field measurements, there is an estimated 32,360 board feet of TWW contained in the Trellis Structure. A breakdown of the TWW by dimensioned lumber size is presented in Table 4

An inventory of ORMs and Universal Wastes that were identified or suspected to be present based on the pre-demolition survey is included in Table 3. A break-down of the treated wood waste (TWW) by wood component size is provided in Table 4.

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CONCLUSIONS AND RECOMMENDATIONS ACM and ACCM

To comply with NESHAP and PUSD requirements, the following asbestos-containing materials (ACMs) and asbestos-containing construction materials (ACCM) will need to be removed prior to demolition of the building:

• Resilient Floor Tile (RFT): RFT (gray-brown with black mastic, 5% Chrysotile) is present in the Janitor Closet (entire floor) and in the North Storeroom (approximate 80% of floor area). The estimated quantity is 110 square feet. The RFT shall be fully removed and disposed of as a Category I NF ACM where removed using manual methods. Where removed using mechanical methods, the RFT shall be handled, packed and transported as RACM (Friable Asbestos, California Hazardous Waste). The removal of the RFT will be coordinated with the removal of the ACCM drywall to minimize the number of containments to be constructed. OSHA Class II work practices shall be utilized.

• Sink with Soundproof Coating: One sink was identified as containing a soundproof undercoat. The sink is in the Work Room in the administration section of the building. The underside of the sink contains an ACM soundproof coating (black, 3% Chrysotile). The sink shall be removed intact using manual methods and OSHA Class II work practices and disposed of as a Category I NF ACM.

• Interior and Exterior Fire-Rated Doors (Suspect ACM core): The interior hallway doors and exterior doors are suspected of containing an ACM core. The number of suspect interior fire doors was estimated to be nineteen (19) with seven (7) suspect exterior fire doors. Prior to the start of abatement, suspect ACM fire doors shall be inspected to determine if they contain asbestos. This would be accomplished by drilling. Doors determined not to contain asbestos can be left in place or salvaged. Doors determined to contain asbestos will need to be removed, handled, packaged and disposed of as RACM (friable asbestos). Friable asbestos is regulated as a hazardous waste in California. This will require transporting the RACM to a NESHAP permitted landfill under a hazardous waste manifest (RACM – Friable Asbestos, California Hazardous Waste).

• Under Slab Vapor Barrier (Suspect ACM): No original construct drawings were available at the time the pre-demolition survey was performed. An under-slab vapor barrier is suspected to be present below the concrete slab on grade floor. Prior to the start of abatement, the concrete slab on grade floor should be cored at a minimum of two (2) locations to determine if an under-slab vapor barrier is present. Where a vapor barrier is observed, the vapor barrier should be sampled and analyzed for asbestos. The vapor barrier is anticipated to cover the full building footprint. The building footprint is estimated to be approximately 12,600 square feet. Where the vapor barrier is found to contain asbestos, demolition practices will be implemented to maintain the vapor barrier in an intact condition while it is being exposed and removed. The vapor barrier shall be removed, handled, packaged and disposed of a CAT I NF ACM.

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• Drywall Joint Compound (ACCM): The existing drywall system, except for the counseling office renovation area (former Classroom 18), was determined to be an ACCM (<0.25% to 0.5% Chrysotile). PUSD will require that the ACCM drywall system be removed prior to demolition of the building. Based on the building layout, an estimated 16,000 square feet of drywall is present. The drywall will be removed by putting the entire building within a Negative Pressure Enclosure (NPE). OSHA Class II work practices will also be utilized.

• Blackboard Shim Tile: Based on a previous classroom renovation, the original slate blackboards are anticipated to have shim tiles glued to the backside of the blackboard. Individual shim tiles are glued together to form a stack. The shim tiles are classified as ACCM (<25% Chrysotile). There is one original blackboard in each classroom. Assuming 8 blackboards, the quantity of blackboard shim tile was estimated to be approximately 45 square feet. PUSD will require that the ACCM shim tiles be removed prior to demolition of the building. The removal of the ACCM shim tile should be coordinated with the removal of the ACCM drywall. OSHA Class II work practices will also be utilized.

• Regulatory Requirements: Since the quantity of the ACM is greater than 100 square feet, the removal of the ACM will require the contractor to have DOSH registration as an asbestos abatement contractor for removal of the ACM. The contractor will also need to be a California licensed asbestos contractor1 and use asbestos trained workers and supervisor to remove the ACMs and ACCMs. During removal of the ACMs and ACCMs, work practices and regulatory notifications identified in the OSHA Asbestos in Construction Standard [CAL OSHA 1529] and BAAQMD Regulation 11, Rule 2 will need to be implemented by the asbestos abatement contractor. This will require the use of containment (NPE), regulated areas, wet methods, prompt cleanup of the ACM, placement in a leak-proof container, and perimeter air monitoring. If the contractor does not have a negative exposure assessment, contractor employee’s will need to set up a regulated area and wear appropriate PPE, including respiratory protection. ACMs identified as RACM will need to be removed, handled, packaged and disposed of in conformance with the requirements identified in CAL/OSHA 1529. RACM will need to be transported under a Uniform Hazardous Waste Manifest as Friable Asbestos and EPA Waste Shipment Record. Category I non-friable ACM can be disposed of as Non-hazardous asbestos-containing waste under a non-hazardous waste manifest.

• Demolition of the building will be subject to Federal National Emission Standards for Hazardous Air Pollutants (NESHAP). Materials identified as ACM will need to be removed from the building prior to demolition. All ACM and ACCM removal will be performed within a regulated area including a Negative Pressure Enclosure (NPE).

• Removal of Regulated Asbestos Containing Materials (RACM) greater than 100 square feet will require notification to BAAQMD to obtain a J number. In addition, demolition of the

1 California C-22 specialty license or California Contractor License (Class A or B) and asbestos certification pursuant to Section 7058.5 of the California Business and Professions Code (BPC).

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building is also subject to a NESHAP demolition permitting. NESHAP demolition permitting will require notification to the BAAQMD for the demolition of the building by completing BAAQMD Form 1102 (Demolition Notification).

Lead

• All lead in construction-related work shall be performed in conformance with OSHA Lead in Construction Standard [CAL OSHA 1532.1]

• Vent Pipe Flashing: The lead sheet vent pipe flashing at all five (5) roof vent pipe locations shall be removed. Since the flashing consist of lead sheeting, the lead sheeting should be recycled.

• Demolition Waste Streams - No Additional Characterization: The following lead-containing waste streams were determined not to require additional waste characterization and can remain in the building unless specified elsewhere to be removed as apart of asbestos abatement, for recycling and/or reclamation or salvaged for reuse by the PUSD:

▪ Interior Painted Wood Trim, Door, and Door Casing Paint - All painted wood wall trim, wood doors and wood door casings located in the interior of the building. Wood doors classified as fire doors are to be removed and handled a RACM.

▪ Interior Metal Lockers and Metal Door Systems - All painted metal lockers (hallways), metal doors and metal door frames in the interior of the building. Metal doors classified as fire doors are to be removed and handled a RACM.

▪ Exterior Metal Door and Window Systems - All metal doors and metal door frames on the exterior of the building. Metal doors classified as fire doors are to be removed and handled a RACM.

▪ Ceramic Tile Wall Systems – Green ceramic wall tile and brown ceramic floor tile in exterior accessed restrooms

▪ Exterior Painted Wood Window Casing – All painted wood surround casing on the exterior of the building.

• Demolition Waste Streams- Additional Characterization Required: The following demolition waste streams were determined to need additional waste characterization to establish removal and disposal requirements:

▪ Waste Stream WS-1: White Pebble Texture Coat over concrete substrate – Interior column faces of all sixteen (16) columns located along exterior walls of the building.

▪ Waste Stream WS-2: White Pebble Texture Coat over concrete substrate – Exterior faces of columns on the building (sixteen columns) and all exterior columns that support the wood Trellis/Portico structure (thirteen columns).

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▪ Waste Stream WS-3: White Stucco Texture Coat over concrete substrate – on the exterior building wall faces.

The demolition waste streams WS-1, WS-2, WS-3 will need to be tested for total lead (TTLC) and soluble lead (WET and TCLP) to determine if the components will need to be disposed of as Construction Debris, Non-RCRA California Regulated HW - Lead or RCRA Hazardous Waste – lead. The lead waste characterization procedure is shown in Figure 6.

• Demolition Waste Stream Sampling Methods: The specific method for sampling procedure for waste streams WS-1, WS-2, WS-3 will depend on if the concrete will be recycled or if the concrete will be disposed of to a Class II/III landfill. The specific sampling methods include the following methods:

▪ Method #1 – Concrete is Recycled: Based on discussion with local concrete recyclers, concrete to be recycled must be free of all paint coating systems that contain lead. This will require removal of the paint coating systems from the following building components and/or waste stream:

➢ Waste Stream #1: Building Columns (interior column faces) – The white pebble texture paint coating is present on the interior column faces of all columns located around the perimeter of the building. Based on the site drawing, there are a total of sixteen (16) columns. The texture coat is applied to interior surfaces of the concrete columns for the full interior room height. The interior column faces are estimated to contain approximately 650 square feet of the white pebble texture paint coating.

➢ Waste Stream #2: Building Columns (exterior faces) and Trellis/Portico Structure Columns: The white pebble texture paint coating is present on the exterior faces of all the building columns and on all the columns that support the trellis/portico structure. Based on the site drawing, there are a total of sixteen (16) building columns and thirteen (13) trellis/portico structure columns. The texture coat is applied to the full height of the columns. The exterior building column faces and the trellis/portico structure columns are estimated to contain approximately 2,250 square feet of the white pebble texture paint coating.

➢ Waste Stream #3: Exterior Building Walls: A white texture stucco coat is present on the exterior face of all exterior walls. The exterior walls are estimated contain approximately 5,400 square feet of the white texture stucco coat.

The individual waste streams will need to be kept separate for waste characterization purposes. Representative bulk samples from each waste stream will need to be collected. The sampling of each waste stream should follow procedures detailed in EPA SW-846. This will require collecting between three and six representative samples. Samples should be analyzed for total lead and soluble lead as shown in Figure 6.

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▪ Method #2 – Concrete is Not Recycled: Where painted concrete will not be recycled, the demolition contractor will need to determine if additional waste characterization will be necessary to establish a waste profile for the concrete scheduled for disposal. Where determined to be necessary, representative samples will need to be collected. This would require collecting full-depth samples using concrete coring methods.

ORMs and Universal Wastes Other Regulated Materials (ORMs) and Universal wastes that are present in the building will need to be removed. Handling and disposal of each material is discussed below

• Mercury-containing ORMs identified in the building will need to be removed prior to demolition of the building and disposed of in conformance with applicable laws and regulations. These include mercury-containing fluorescent lights (tubes and CFLs), thermostats, thermometers, and switches. A total of two hundred forty-eight (248) fluorescent light fixtures were observed. Each light fixture is assumed to contain four tubes.

• PCB-containing ORMs identified in the building will need to be removed prior to demolition of the building and disposed of in conformance with applicable laws and regulations. These include PCB-containing light ballasts. The total quantity of ballasts was estimated to be two hundred forty-eight (248) based on the observed quantity of fluorescent light fixtures.

• There are four (4) roof-mounted HVAC package units. Each HVAC package unit is anticipated to contain oil and refrigerant. These chemicals are considered ozone-depleting chemicals. The oil and refrigerant shall be removed and be recycled by an EPA-certified HVAC technician.

• Smoke detectors were identified as part of the fire alarm system in the building. All smoke detectors are to be removed prior to building demolition. The locations of the smoke detectors are shown the fire alarm plan for the building (See Appendix C). The smoke detectors may contain either low-level radioactive or electronic components that will require recycling or special disposal.

• Heat detectors and other fire alarm components were identified as part of the fire alarm system in the building. All heat detectors and other fire alarm components are to be removed prior to building demolition. The locations of the heat detectors are shown the fire alarm plan for the building (See Appendix C). The heat detectors and other fire alarm components may contain electronic components that will require recycling or special disposal.

• PUSD will not reclaim the pressure treated wood in Trellis/Portico structure or the building window trellis sun shade. All pressure treated wood will need to be handled and disposed of as Treated Wood Waste (TWW) under the alternative management standards (AMS) under California Code of Regulations, Title 22, Division 4.5, Chapter 34. This will require disposal to Class II/III landfill permitted to receive TWW.

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Additional Considerations - Concrete A January 2014 EPA Regulatory Determination in response to a letter from the California Air Resources Board determined that concrete should be considered as a suspect ACM. The determination applies to heavy concrete structures, boiler housekeeping pad, and similar structures. In addition, subsequent EPA guidance has stated that where more than 160 square feet of concrete will be demolished and recycled, the concrete should be tested for asbestos. At present, BAAQMD is recommending that concrete that will be recycled be tested for asbestos. Local concrete recyclers that were contacted indicated that they do not require asbestos testing documentation. However, some local landfills have begun requiring documentation that the concrete has been tested for asbestos and requiring concrete with regulated levels of asbestos (asbestos content greater than 1%) to be properly packaged and transported in conformance with NESHAP and CAL/OSHA regulations. Based on the above, a supplemental survey was conducted. The concrete foundation system was sampled and was found not to contain asbestos. However, the general contractor and/or demolition contractor may need to perform additional sampling of concrete where required by concrete recyclers or by Class II/III landfills for waste profiling and acceptance.

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TABLE OF CONTENTS

SECTION .................................................................................................................................................................. PAGE

EXECUTIVE SUMMARY ............................................................................................................................................... I 1.0 INTRODUCTION ..................................................................................................................................................... 1

1.1 PROJECT LOCATION AND UNDERSTANDING .................................................................................... 1 1.2 SITE DEMOLITION AND REGULATORY REQUIREMENTS ............................................................ 1 1.3 PRE-RENOVATION HAZARDOUS MATERIALS SURVEY SCOPE OF WORK ............................ 2 1.4 REPORT ORGANIZATION .............................................................................................................................. 4

2.0 BUILDING CONSTRUCTION INFORMATION SUMMARY ..................................................................... 5 2.1 RENOVATION HISTORY ................................................................................................................................. 5 2.2 BUILDING CONSTRUCTION ......................................................................................................................... 5

3.0 HAZARDOUS MATERIAL SURVEY .................................................................................................................. 6 3.1 HAZMAT SURVEY SUMMARY ....................................................................................................................... 6 3.2 ACM SURVEY ........................................................................................................................................................ 6

3.2.1 ACM Survey Overview ................................................................................................................................... 6 3.2.2 Survey Areas Found to Contain Asbestos ................................................................................................... 7 3.2.3 Survey Areas Not Sampled but Assumed to Contain Asbestos ............................................................... 8 3.2.4 Survey Areas Found Not to Contain Asbestos ........................................................................................... 8

3.3 LEAD SURVEY ...................................................................................................................................................... 8 3.3.1 Lead Survey Overview and Assessment Methodology .............................................................................. 8 3.3.2 Lead Survey Findings – Lead-Based Paint/Building Components.......................................................... 9 3.3.3 Lead Survey Findings – Lead-Containing Paint/Building Components .............................................. 10 3.3.4 Lead Survey Findings – Preliminary Waste Characterization ................................................................. 10

3.4 OTHER HAZARDOUS MATERIALS ........................................................................................................... 12 3.4.1 ORMs and Universal Wastes ........................................................................................................................ 12 3.4.2 Electronic Wastes ........................................................................................................................................... 14 3.4.3 Treated Wood Waste (TWW) ...................................................................................................................... 14

3.5 MOLD ..................................................................................................................................................................... 14 3.6 NATURALLY OCCURRING ASBESTOS .................................................................................................... 14

4.0 REGULATORY CONSIDERATIONS ............................................................................................................... 15 4.1 HAZARDOUS MATERIAL WORK - REGULATORY NOTIFICATIONS ........................................ 15 4.2 WORKER PROTECTION AND WASTE DEFINITIONS FOR ASBESTOS ..................................... 15 4.3 WORKER PROTECTION AND WASTE DEFINITIONS OF LEAD (IN PAINT AND CONSTRUCTION MATERIALS) .......................................................................................................................... 16 4.4 WORKER PROTECTION FOR RESPIRABLE SILICA ........................................................................... 17 4.5 CONSTRUCTION AND DEMOLITION DEBRIS MANAGEMENT ................................................. 17 4.6 OTHER APPLICABLE REGULATIONS ..................................................................................................... 18

4.6.1 California Health and Safety Code (Cal H&SC) ....................................................................................... 18 4.6.2 Proposition 65 ................................................................................................................................................ 18 4.6.3 Hazardous Waste Criteria ............................................................................................................................. 19

5.0 CONCLUSIONS AND RECOMMENDATIONS ............................................................................................ 20 5.1 ACM AND ACCM ............................................................................................................................................... 20 5.2 LEAD ...................................................................................................................................................................... 22 5.3 ORMS AND UNIVERSAL WASTES .............................................................................................................. 24 5.4 ADDITIONAL CONSIDERATIONS - CONCRETE ................................................................................ 25

6.0 LIMITING CONDITIONS .................................................................................................................................... 26

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LIST OF TABLES Table No. Title Page Table 1 – ACM Building Material Sample Results .................................................................................... T-1 Table 2 – Bulk Lead Results ........................................................................................................................ T-9 Table 3 – ORM and Universal Waste Inventory ................................................................................... T-11 Table 4 – TWW Board Inventory ............................................................................................................ T-12

LIST OF FIGURES Figure No. Title Page Vicinity Map.................................................................................................................................................... F-1 Site Plan ........................................................................................................................................................... F-2 Building Interior Bulk Sample Location Plan ............................................................................................ F-3 Roof and Building Exterior Bulk Sample Location Plan ......................................................................... F-4 Building Interior and Exterior Lead XRF Summary ............................................................................... F-5 Characterization and Disposal of Lead Waste Streams ............................................................................ F-6 List of Appendices Appendix A .................................................................... Asbestos and Lead Analytical Laboratory Reports Appendix B .......................................................................................................................XRF Survey Reports Appendix C .......................................................................... Administration Building Fire Alarm Drawings Appendix D ....................................................................................................................................... Photo Log Appendix E ....................................................................... Regulatory Information and Notification Forms Appendix F ................................ Hazardous Material Specifications and Hazardous Material Drawings* *Appendix F will be presented in a separate submittal.

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ACRONYM GUIDE

ACM Asbestos-Containing Material

ACCM Asbestos-Containing Construction Material

Cal OSHA California Occupational Safety and Health Administration

CCR California Code of Regulations

CDPH California Department of Public Health

CFR Code of Federal Regulations

CPSC Consumer Product Safety Commission

DOSH California Department of Safety and Health

EPA Environmental Protection Agency

HSG Homogeneous Sampling Group

HUD U.S. Department of Housing and Urban Development

HVAC Heating Ventilation and Air Conditioning

LBP Lead-Based Paint

NEA Negative Exposure Assessment

NESHAP National Emission Standards for Hazardous Air Pollutants

PLM Polarized Light Microscopy

ppm Parts per million

PQL Practical Quantification Limit

RACM Regulated Asbestos Containing Material

RFT Resilient Floor Tile

STLC Soluble Threshold Limit Concentration

(California soluble metal waste characterization)

TSI Thermal System Insulation

TCLP Toxic Characteristic Leaching Potential

(Federal soluble metal waste characterization: RCRA and Non-RCRA

TTLC

TWW

Total Threshold Limit Concentration

(California total metal waste characterization)

Treated Wood Waste

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1.0 INTRODUCTION 1.1 PROJECT LOCATION AND UNDERSTANDING Piedmont Unified School District (PUSD) intends to demolish the existing Administration Building (Building D), Trellis Structure and associated concrete surface treatments in the immediate vicinity of the Administration Building. The Administration Building is also identified historically as the 10’s Building. The Administration Building is part of the Piedmont High School Campus operated by PUSD. The Piedmont High School Campus is located at 800 Magnolia Avenue in Piedmont, CA. The Piedmont High School Campus site is shown in relation to the surrounding area on the Vicinity Map, Figure 1. The Administration Building is also shown in relation to the Piedmont High School Campus on Figure 1. The approximate demolition limits are shown in Figure 2. The demolition of the Administration Building will be subject to removal of hazardous materials covered under the federal NESHAP Regulation. To comply with NESHAP, a demolition-level hazardous material survey was conducted by Milani & Associates under contract to Piedmont Unified School District (PUSD). 1.2 SITE DEMOLITION AND REGULATORY REQUIREMENTS The approximate limits of demolition for the Administration Building Demolition Project are shown in Figure 2. The scope of the demolition includes the following:

• Removing building components scheduled to be salvaged,

• Performing necessary hazardous material removal and abatement prior to building demolition,

• Removing the wood trellis/portico roof structure and wood trellis-style sunshades,

• Demolishing the Administration Building,

• Demolishing the concrete building foundation system and concrete surface treatments scheduled for demolition, and

• Performing limited site grading. The demolition will include segregation of demolition waste streams for recycling and disposal. This will include separating pressure treated wood for disposal as Treated Wood Waste (TWW) where the pressure treated wood is not going to be reclaimed for reuse. The demolition of the structure will be subject to removal of hazardous materials and demolition permitting under the federal NESHAP regulation and Bay Area Air Quality Management District (BAAQMD) Regulation 11, Rule 2. To comply with the NESHAP regulation and BAAQMD regulations, a demolition-level hazardous material survey was conducted by Milani & Associates under contract to the Piedmont Unified School District (PUSD). The pre-demolition hazardous materials survey included the following elements:

• Inspecting and sampling the structure for Regulated Asbestos Containing Material (RACM) for compliance with the federal NESHAP regulation and applicable federal and state Occupational Safety and Health Administration (OSHA) regulations,

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• Inspecting and sampling the structure (interior, exterior and roof) for Regulated Asbestos Containing Material (RACM) for compliance with the federal NESHAP regulation and applicable federal and state Occupational Safety and Health Administration (OSHA) regulations,

• Evaluating and sampling the structure (interior, exterior, roof and concrete foundation) for Category I Non-Friable (CAT I NF) and Category II Non-friable (CAT II NF) Asbestos Containing Materials (ACMs). The evaluation included assessing if these materials could be made friable during the demolition of the building. Where these materials could be made friable during demolition, these materials would be re-classified as RACM and would be subject to the federal NESHAP regulation, applicable federal and state Occupational Safety and Health Administration (OSHA) regulations, and Bay Area Air Quality Management District (BAAQMD) regulations covering building renovation and/or demolition,

• Evaluating and sampling building materials, building components and paint coating systems for lead using bulk sampling and nondestructive X-ray fluorescence (XRF) testing for initial waste characterization purposes, and

• Inspecting the structure for the presence of Other Regulated Materials (ORMs) and Universal Wastes that may require removal prior to demolition, may require special handling and packaging or may require waste profiling to determine appropriate disposal.

• Sampling the concrete foundation system for asbestos as part of a supplemental survey. The scope of the pre-demolition survey did not include performing a mold survey, or sampling of the sub-slab vapor barrier or sampling of the underground utilities (electrical, water, sewer) for asbestos. The scope of the pre-demolition survey did not include collection and analysis full depth samples of add-on texture coats with lead-containing or lead-based paint coating systems for waste characterization. The hazardous material survey also excluded testing soil for Naturally Occurring Asbestos (NOA). Soil testing for NOA was performed by the project geotechnical consultant. 1.3 PRE-RENOVATION HAZARDOUS MATERIALS SURVEY SCOPE OF WORK Milani & Associates was requested by PUSD to perform a pre-demolition Hazardous Material Survey for Asbestos-Containing Materials (ACMs); Lead-based paint (LBP) and/or Lead-containing paint (LCP; and Other Regulated Materials and Universals Wastes within the Administration Building. Milani & Associates performed the following scope of services in conformance with Milani and Associates’ proposal dated July 11, 2017:

1. Review of Available Documents – Prior to the initial site inspection, the following documents were reviewed:

• University Associates, LTD., “Asbestos Inspection Report and Asbestos Hazard Emergency Response Act (AHERA) Management Plan, Piedmont High School”, dated May 1, 1988.

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• J. A. Townsley Company, Inc., “Asbestos Triannual Re-inspection Report, Piedmont High School”, dated 1991.

• J. A. Townsley Company, Inc., “Asbestos Triannual Re-inspection Report, Piedmont High School”, dated 1994.

• Millennium Consulting Associates, “Hazardous Materials Survey Report - Fire Alarm Alignment – Piedmont High School”, dated September 3, 2009.

• Milani & Associates, “Limited ACM Survey, Inspection, and Testing, Blackboard Replacement and Disposal, Administration and Classroom Building "D", Classroom 12", dated December 5, 2016.

The results of the review were incorporated into the sampling and analysis plan and findings for the pre-demolition survey. Analytical results from the fire alarm hazardous material survey and blackboard replacement project were incorporated into Tables 1 and 2 as appropriate.

2. ACM Survey – An ACM survey of the structure was performed in accordance with the listed

criteria in California Occupational Safety and Health Administration (Cal OSHA) standard under Title 8 California Code of Regulations (CCR) 1529, OSHA standard Title 29 Code of Federal Regulations (CFR) 1926.1101 and Environmental Protection Agency (EPA) standard Title 40 CFR Section 61.145 Subpart M (NESHAP regulation standard for demolition/renovation), including the analysis of bulk samples via polarized light microscopy (PLM) methodology.

The ACM survey was limited to the building interior, building exterior, building roof, building foundation system and associated wood trellis/portico roof and wood trellis sunshade areas of the building that are scheduled for demolition. The survey excluded underground utilities.

3. Lead Paint and Component Survey - A survey of the building was conducted for the presence

of lead-containing building components, lead-based paint (LBP) and lead-containing paint (LCP). The assessment for lead-containing components, LCP and LBP included bulk sampling of ceramic tile building components and conducting a non-destructive X-ray fluorescence (XRF) lead survey of the interior, exterior and roof of the structure. The XRF survey was used to analyze painted surfaces and architectural components for lead presence. Bulk samples of ceramic tile systems were tested for total lead for initial characterization for total lead (TTLC).

4. Other Regulated Materials (ORM) and Universal Waste Survey - A visual inventory and

reconnaissance of lighting and heating systems in the building for mercury and/or PBC containing devices (fluorescent light ballasts, fluorescent light tubes, and thermostats) were performed. The survey also included a visual inventory of low-level radioactive containing materials and components containing ozone-depleting chemicals where these components were observed to be present. An inventory of Treated Wood Waste (TWW) was also generated where pressure treated wood would be generated as a demolition waste stream.

5. Supplemental Survey – A supplemental survey was conducted on May 10, 2018, to sample the concrete foundation system for the building for asbestos.

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6. Written Report - A written report was prepared to detail the survey information including a description of the samples and sample locations, analytical results in tabular form, the condition of surfaces identified, findings, interpretation of results, and recommendations.

The survey was limited to the interior, exterior and roof areas of the building. The Administration Building was in active use at the time the survey was performed. The initial pre-demolition survey was conducted on July 13, 2017. A supplemental survey was conducted on May 10, 2018. Reasonable efforts were made to access all areas and locate conditions/materials representative of the structure. The general site access was made available by PUSD. Survey activities were performed by Mr. Mark Milani, Cal/OSHA Certified Asbestos Consultant 08-4469 and CDPH Certified Lead Inspector/Assessor #21323 and Mr. Jerry Lee, Environmental Technician with Milani & Associates. Previous asbestos and lead data from prior hazardous material surveys and waste characterization were utilized as reported. The scope of the pre-demolition survey did not include performing a mold survey, sampling of an under slab vapor barrier or underground utilities (electrical, water, sewer) for asbestos. 1.4 REPORT ORGANIZATION The Pre-Demolition Survey Report is organized into six (6) sections. Section 1 defines the scope of the pre-demolition survey. Section 2 summarizes information known about the construction materials observed in the structures that were subject to the survey. Section 3 presents the results of the ACM, Lead Paint and Other Regulated Materials (ORM) survey and analyses of bulk samples. Section 4 discusses regulatory considerations. Section 5 presents conclusions and recommendations developed as part of the Pre-demolition survey. Section 6 presents limitations. Figures and tables referenced in the report are presented in the tabbed Figures and Tables section of the report. The asbestos test results and lead results are tabulated in Tables 1 and 2, respectively. An inventory of ORMs and Universal Wastes that were identified or suspected to be present based on the pre-demolition survey is included in Table 3. A break-down of the treated wood waste (TWW) by wood component is provided in Table 4. Copies of asbestos and lead test results are presented in Appendix A. A copy of the XRF report is included in Appendix B. A copy of the Fire Alarm Drawings for the Administration Building are included in Appendix C. A photo log is included in Appendix D. Regulatory information and notification forms are included in Appendix E. Hazardous material specifications and drawings for asbestos abatement, lead in construction work and removal and disposal of ORMs are included in Appendix F. Appendix F will be prepared as a separate submittal from the pre-demolition survey report.

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2.0 BUILDING CONSTRUCTION INFORMATION SUMMARY 2.1 RENOVATION HISTORY Based on a review of the AHERA management report, the Administration Building was originally constructed in 1978. PUSD personnel indicated that in the 1990’s, Classroom 18 was converted for use as counseling offices. The Classroom 18 conversion to counseling offices included installation of new partition walls, carpet, drop ceiling system, new HVAC ducting and new lighting. The original lighting system for Classroom 18, which is located above the new drop ceiling, was disconnected but not removed. 2.2 BUILDING CONSTRUCTION The Administration Building is approximately rectangular and occupies about 12,500 square feet. The building consists of exterior perimeter concrete columns with concrete tilt-up infill panels. The building is supported on a concrete slab-on-grade floor. The building does not have a crawl space. The building roof system consists of a wood diaphragm with a conventional built-up roof system. A wood-frame clay-tile screen system surrounds the roof-mounted HVAC units. Windows and exterior doors are constructed with metal frames. The building roof is surrounded by a wood trellis/portico roof system on the south side of the building and by wood trellis-style sun shades along the north, east and west sides of the building. Portions of the wood trellis and wood trellis style sunshades are constructed with pressure treated wood. The interior walls of the structure are finished with conventional drywall construction throughout the interior of the building. The exterior columns project into the interior building space. Ceilings in the classrooms and interior office areas are generally open exposing the wood underdeck of the roof diaphragm roof. The counseling office (former Classroom 18) has a drop ceiling with lay-in ceiling tiles with integrated suspended lights. The original light fixtures associated with former classroom use are present above the suspended ceiling system. The two exterior accessed restrooms have drywall ceilings. The flooring systems include conventional resilient floor tiles in the interior hallways and classrooms. The administration offices that comprise the central core of the building and the counseling office have carpet. The two restrooms are constructed with ceramic tile floors and full height ceramic tile walls. Rubber cove base of various colors is present throughout the building. The building was observed to contain four roof-mounted HVAC units. Interior HVAC ductwork is suspended from the ceiling and exposed. All exposed ductwork in the building interior uses mechanical connections. Exterior ductwork on the roof was observed to have duct tape on most connections. Mastics and/or sealants were present at all roof penetrations and counter flashings. All roof vents have lead sheeting flashings. The interior of the HVAC units could not be accessed. However, each unit is thought to contain a compressor and refrigerant reservoir.

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3.0 HAZARDOUS MATERIAL SURVEY 3.1 HAZMAT SURVEY SUMMARY The survey was limited to the interior, exterior and roof areas of the building. The Administration Building was in active use at the time the survey was performed. The pre-demolition survey was conducted on July 13, 2017. A supplemental survey was performed on May 10, 2018. Reasonable efforts were made to access all areas and locate conditions/materials representative of the structure. The general site access was made available by PUSD. Survey activities were performed by Mr. Mark Milani, Cal/OSHA Certified Asbestos Consultant 08-4469 and CDPH Certified Lead Inspector/Assessor #21323 and Mr. Jerry Lee, Environmental Technician with Milani & Associates. Previous asbestos and lead data from prior hazardous material surveys and waste characterization were utilized as reported. The scope of the pre-demolition survey did not include performing a mold survey, sampling of sub-slab vapor barrier systems or underground utilities (electrical, water, sewer) for asbestos. The hazardous material survey also excluded testing soil for Naturally Occurring Asbestos (NOA). Soil testing for NOA was performed by the project geotechnical consultant. 3.2 ACM SURVEY 3.2.1 ACM Survey Overview A preliminary walk-through of the structure was performed to familiarize the inspectors with the structures and to identify suspect ACM containing components. During the walk-through, heating, ventilation and air conditioning (HVAC) ducting; hot and cold water supply piping; other mechanical systems requiring thermal system insulation (TSI); and other suspect applications that were readily accessible were inspected for suspect asbestos-containing TSI, where present. The interior and exterior of the building were assessed for suspect Regulated Asbestos Containing Materials (RACM) including suspect asbestos-containing surfacing materials and suspect asbestos-containing miscellaneous friable materials. The interior and exterior of the building were also assessed for suspect asbestos-containing Category I non-friable (CAT I NF) materials and suspect asbestos-containing Category II non-friable materials (CAT II NF). Friable materials (RACM) are defined as materials that when dry, can be crumbled or reduced to a powder by hand pressure. Category I non-friable materials are defined as packing, gaskets, asphaltic roofing materials, and resilient flooring materials and associated mastics in which the asbestos fibers are bound within a resinous matrix. Category II non-friable materials are defined as other non-friable materials such as transite in which the asbestos fibers are bound within a cement-like matrix. During the walk-through, homogeneous sample groups (HSGs) were identified. Based on the identified HSG and understanding of each building’s history, a bulk-sampling plan for suspect ACM was developed. Bulk sampling was conducted in accordance with modified procedures outlined in the Asbestos Hazard Emergency Response Act (40 CFR 763.86, Sampling). The procedure requires the inspector to select random sampling locations from homogeneous materials suspected to contain asbestos.

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Fifty-five (55) suspect ACM bulk samples were collected from the interior and exterior of the building and from the asphalt and concrete pavement systems. The samples were sealed in uniquely labeled bags and shipped under chain-of-custody procedures to EMSL Analytical Laboratories (EMSL) located in San Leandro, CA. EMSL is accredited by the National Institute of Standards and Technology’s National Voluntary Laboratory Accreditation Program (NVLAP) for the analysis of asbestos in bulk samples by EPA Method 600/R-93/116. Asbestos analyses included analysis by standard PLM. This was augmented by point counting (400-point count) on selected bulk samples where samples were identified as containing trace asbestos (Trace [<1% asbestos]). In addition, all drywall joint compound found to contain asbestos at less than 3% asbestos were also subject to 400-point count. The bulk sample locations are shown on the Bulk Sample Location Plans, Figures 3 and 4. The results of the asbestos analyses are presented in sections 3.2.2, 3.2.3, and 3.2.4, and are tabulated in Tables 1A, 1B, and 1C. A copy of EMSL’s NVLAP Certification is included in Appendix A.

3.2.2 Survey Areas Found to Contain Asbestos The summarized inventory of materials tested and found TO CONTAIN asbestos at concentrations greater than 1% that are regulated under AHERA as TSI, Surfacing and Miscellaneous and regulated under NESHAPS as CAT I NF, CAT II NF or RACM are described below: Building Interior:

• Resilient Floor Tile (RFT), gray-brown with black mastic, 5% Chrysotile [Miscellaneous/Category I NF ACM]

• Sink Soundproof Coating, black (1), 3% Chrysotile [Miscellaneous/Category I NF ACM] Building Exterior and Roof:


• None Identified

The summarized inventory of materials tested and found TO CONTAIN asbestos at concentrations regulated under OSHA (greater than 0% but less than or equal to 1%) is described below: Building Interior:

• Drywall Joint Compound, <0.25% to 0.5% Chrysotile (ACCM), by PLM 400-point count

• Blackboard Shim Tile, <25% Chrysotile (ACCM), by PLM 400-point count

The shim tiles are located behind the original blackboards in all classrooms.

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Building Exterior and Roof:


• None Identified

3.2.3 Survey Areas Not Sampled but Assumed to Contain Asbestos

Based on the results of the visual inspection, the summarized inventory of materials that are SUSPECT AND/OR ASSUMED TO CONTAIN asbestos is described below: Building Interior:

• Interior fire-rated doors through-out Building Exterior and Roof:

• Exterior fire-rated doors on the south side of the building Site Exterior and Concrete Foundation:

• Vapor barrier under the concrete slab on grade floor (where present) Prior to the start of abatement, suspect ACM fire doors should be inspected to determine if they contain asbestos. This would be accomplished by drilling. In addition, the concrete slab on grade floor should be cored at a minimum of two (2) locations to determine if an under-slab vapor barrier is present. Where a vapor barrier is observed, the vapor barrier should be sampled and analyzed for asbestos.

3.2.4 Survey Areas Found Not to Contain Asbestos The summarized inventory of materials tested and found NOT TO CONTAIN asbestos, according to survey work, are identified in Table 1A for the building interior, in Tables 1B and 1C for the building exterior and roof. 3.3 LEAD SURVEY 3.3.1 Lead Survey Overview and Assessment Methodology Milani and Associates conducted a lead survey of the building. The assessment for lead-containing components, LCP and LBP included bulk sampling of ceramic tile building components and conducting a non-destructive X-ray fluorescence (XRF) lead survey of the interior, exterior and roof of the structure. An RMD Model LPA-1 XRF Analyzer (Serial No. 03494) was used to conduct the XRF Survey. The XRF survey was used to analyze painted surfaces and architectural components for lead presence.

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Four (4) bulk samples were collected from the ceramic tile systems observed in the two exterior restrooms. The lead bulk samples were sealed in uniquely labeled bags and shipped under chain-of-custody procedures to EMSL Analytical Laboratories (EMSL) located in San Leandro, CA. EMSL is certified by the California Department of Health Services Environmental Laboratory Accreditation Program for the various EPA and SW-846 Test Methods utilized for lead testing. A copy of EMSL’s California ELAP Certification is included in Appendix A. A copy of the lead XRF report is included in Appendix B. Bulk sampling for lead was performed in accordance with industry standards in existence at the time of the project. The XRF survey was performed in accordance with industry standards in existence the time of the project. Sample locations were determined based on the building components and paint coating systems observed during the inspection. The results of the lead bulk and lead waste characterization are presented in Tables 2A and 2B, respectively.

3.3.2 Lead Survey Findings – Lead-Based Paint/Building Components The following is a list of building components and/or paint coating systems that were found to contain lead at or above the federal standard for lead-based paint (5,000 ppm or 0.5% by weight, or ≥1.0 mg/cm2). All homogeneous components located throughout the building shall be assumed as having similar concentrations: Interior:

• White Pebble Texture Coat (1.0 mg/cm2) – Interior column faces of all sixteen (16) columns located along exterior walls.

Exterior:


• White Stucco Texture Coat (1.0 mg/cm2) – Eastside building wall face.

• Lead Sheet Pipe Flashing (99% inorganic lead) - At all five (5) roof pipe vent locations Lead concentrations reported in ppm or percent by weight were determined by bulk sample analysis. Lead concentrations reported in mg/cm2 were determined by XRF. The XRF survey report is included in Appendix B. Note: Only the exterior columns on the east and north side of the Administration Building contain the lead-based white pebble texture coat. The exterior building columns on the south and west side and the columns that support the trellis/portico structure on the south side of Administration Building have a lead-containing white pebble texture coat.

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3.3.3 Lead Survey Findings – Lead-Containing Paint/Building Components The following is a list of building components and paint coating systems that were found to contain lead at concentrations below the federal standard for LBP (<5000 ppm, or 0.5% by weight or less than 1.0 mg/cm2). Building components and paint coating system with lead concentrations below the federal standard for LBP are considered Lead-Containing Materials and are regulated by both Cal/OSHA and EPA. All homogeneous components shall be assumed to contain similar concentrations: Interior:

• Paint Coating Systems (various colors - <100 ppm) – all interior painted wall and hard ceiling systems located in the interior of the building.

• Paint Coating System (various colors - 0 mg/cm2) – all interior painted wall trim located in the interior of the building.

Exterior:


• White Pebble Texture Coat (0.2 – 0.5 mg/cm2) – Exterior faces of columns on the south side (six columns) and the west side (four columns) of the building and all exterior columns that support the wood Trellis/Portico structure (thirteen columns).

See Table 2A for results of paint chip analyses. The results of the XRF survey are included in Appendix B. Note: Should construction finishes with “detectable” concentrations of lead be disturbed, OSHA compliance measures and waste characterization measures for all lead-containing waste streams will be required.

3.3.4 Lead Survey Findings – Preliminary Waste Characterization As part of the hazardous material survey, preliminary waste characterization of selected building demolition waste streams for lead was performed to determine if the waste streams will need to be handled and disposed of a hazardous waste. Both XRF and bulk lead sample data were used for the preliminary waste characterization. The selected waste streams on which preliminary waste characterization was performed included the following: Interior:

• Ceramic Tile Wall Systems (bulk sample for total lead) – exterior accessed restrooms

• Ceramic Tile Floor Systems (bulk sample for total lead) – exterior accessed restrooms

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Exterior:

• White Pebble Texture Coat (XRF) – all exterior faces of building exterior columns

• White Stucco Texture Coat (XRF) – on selected exterior building wall faces

• White Pebble Texture Coat (XRF) – all exterior columns that support the wood Trellis/Portico structure.

The results of the bulk lead sample analyses are included in Tables 2A and 2B. The XRF results are included in the XRF survey reports included in Appendix B. The results of the preliminary waste characterization are presented below. The following is a list of components that contained concentrations of lead from bulk sample analyses (total lead) that resulted in concentrations above the California Total Threshold Limit Concentration (TTLC ≥1000 mg/kg by weight) that will require removal and disposal as a California Regulated Hazardous Waste for lead: Interior: None Exterior: None Based on the initial bulk lead sampling, no additional soluble lead testing (California Waste Extraction Test [WET] or Federal Toxic Characteristic Leaching Procedure [TCLP]) were determined to be necessary for the ceramic tile systems. The following is a list of building finishes and/or components identified through the XRF survey that could contain concentrations of lead (total lead) above the California Total Threshold Limit Concentration (TTLC ≥1000 mg/kg by weight): Building Interior Columns:

• The interior columns were found to have a white pebble texture coat (0.4 to 1.0 mg/cm2). The texture coat is located on all the interior column faces at exterior walls. The texture coat is applied to interior surfaces of the concrete columns for the full interior room height. The substrate under the pebble texture coat is concrete.

Exterior:

• The faces of all exterior columns were observed to have a white pebble texture stucco coat (0.5 to 1.0 mg/cm2). The pebble texture coat is located on all exterior faces of both the building exterior columns and the trellis/portico support columns. The substrate under the pebble texture coat is concrete.

• The faces of all exterior walls were observed to have a white texture stucco coat (0.2 to 1.0 mg/cm2). The texture stucco coat is located on all exterior wall faces of building exterior. The substrate under the texture coat is concrete.

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The building components identified above will need to be tested for total lead (TTLC) and soluble lead (WET and TCLP) to determine if the components will need to be disposed of as Non-RCRA or RCRA Hazardous Waste – lead. The specific method of sampling will depend on if the concrete will be recycled or if it will be disposed of to a Class II/III landfill. The specific sampling methods include the following: Method #1 – Concrete is Recycled: Based on discussion with local concrete recyclers, concrete to be recycled must be free of all paint coating systems that contain lead. This will require removal of the paint coating systems from the following building components and/or waste stream:

• Waste Stream #1: Exterior Building Columns (interior column faces) – There are sixteen (16) columns located around the perimeter of the building. The interior faces of these columns contain a white pebble texture coat containing lead between 0.4 and 1.0 mg/cm2. The texture coat is applied to interior surfaces of the concrete columns for the full interior room height.

• Waste Stream #2: Exterior Building and Trellis/Portico Structure Columns: The exterior faces of all the building columns and the columns that support the trellis/portico structure were observed to have a white pebble texture coat containing lead between 0.5 and 1.0 mg/cm2. The texture coat is applied to the full height of the columns.

• Waste Stream #3: Exterior Building Walls: The faces of all exterior walls were observed to have a white texture stucco coat containing lead between 0.2 and 1.0 mg/cm2. The texture stucco coat is located on all exterior wall faces of building exterior.

The individual waste streams will need to be kept separate for waste characterization purposes. Representative bulk samples from each waste stream will need to be collected. The sampling of each waste stream should follow procedures detailed in EPA SW-846. Samples should be analyzed for total lead and soluble lead as shown in Figure 6. Method #2 – Concrete is Not Recycled: Where painted concrete will not be recycled, the demolition contractor will need to determine if additional waste characterization will be necessary to establish a waste profile for the concrete scheduled for disposal. Where determined to be necessary, representative samples will need to be collected. This would generally require collecting full-depth samples using concrete coring methods. 3.4 OTHER HAZARDOUS MATERIALS

3.4.1 ORMs and Universal Wastes The following ORMs and/or Universal Wastes were observed during the survey or are suspected to be present based on field observation. Quantity estimates for the ORMs and Universal Wastes identified below are presented in Tables 3 and 4:

• Mercury-containing Devices The following mercury-containing devices were observed or are believed to be present:

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1. Fluorescent Lighting Fixtures (Tube) – The interior of the building contains multiple ceiling-mounted tube-style fluorescent light fixtures. A total of two hundred forty-eight (248) fluorescent light fixtures are estimated to be present in the building. For demolition purposes, each light fixture is assumed to contain two to four fluorescent light tubes.

2. Fluorescent Lighting Fixtures (CFL) – While not observed during the survey, the interior of the building may contain ceiling-mounted light fixtures that contain compact fluorescent bulbs (CFLs). For demolition purposes, where present, CFL containing light fixtures are assumed to contain up to two CFLs.

3. Mercury-containing Thermostats – While not observed during the survey, up to four (4)

mercury-containing thermostats are believed to be present. There is believed to be one (1) thermostat for each HVAC unit.

• PCB-containing Device and Materials

The following PCB-containing devices were observed or are believed to be present: 1. Fluorescent lighting fixtures – A total of two hundred forty-eight (248) fluorescent

light fixtures were observed. The fluorescent light fixtures are assumed to contain one ballast, which may contain PCBs. The ballasts were not readily accessible during the survey because they were internally mounted. Internally mounted ballasts that were not able to be observed should be considered to contain PCB’s until removed from the light fixture and verified to be non-PCB containing. The total quantity of ballasts was estimated to be two hundred forty-eight (248) based on the observed quantity of fluorescent light fixtures.

• Low-Level Radioactive Materials (tritium containing exit signs and smoke detectors)

The following Low-Level Radioactive Materials containing components were observed or are believed to be present:

1. Exit Signs – The building was observed not to contain exit signs.

2. Smoke Detectors – The building was observed to contain numerous smoke detectors.

The devices are in hallways, office, and classrooms. The locations of smoke detectors are shown on the fire alarm drawing for the building. A copy of the fire alarm drawing is included in Appendix C.

• Ozone Depleting Chemicals (compressor oils and refrigerants) The following components containing ozone-depleting chemicals were observed or are believed to be present:

1. HVAC System – The building is equipped with four (4) roof-mounted air conditioning

units. The interior of these units could not be accessed. Each unit should be assumed to contain compressor oil and refrigerant.

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3.4.2 Electronic Wastes

The following components that would be classified as electronic wastes that were observed or are believed to be present include the following:

1. Digital Thermostats – While not observed during the survey, up to four (4) thermostats

are believed to be present. There is believed to be one (1) thermostat for each HVAC unit.

2. Digital/Electronic Heat Detectors – The building was observed to contain numerous heat detectors. These devices are in hallways, offices, and classrooms. The locations of the heat detectors are shown on the fire alarm drawing for the building. A copy of the fire alarm drawing is included in Appendix C.

3. Other Electronic Wastes – If other electronic wastes are found, they shall be disposed and/or recycled in conformance with applicable regulations.

The PUSD may require that fire alarm components, including the Fire Alarm Control Plan (FACP), smoke detectors, heat detectors and other components to be salvaged and returned to PUSD.

3.4.3 Treated Wood Waste (TWW)

Portions of the existing Trellis/Portico structure and wood trellis sunshade are constructed using pressure treated wood. The Trellis/Portico structure and wood trellis sun shades are scheduled for demolition. The pressure treated wood waste stream generated from this demolition would be considered treated wood waste (TWW). Base on the visual survey and field measurements, there is an estimated 32,360 board feet of TWW contained in the Trellis Structure. A breakdown of the TWW by dimensioned lumber size is presented in Table 4

An inventory of ORMs and Universal Wastes that were identified or suspected to be present based on the pre-demolition survey is included in Table 3. A break-down of the treated wood waste (TWW) by wood component size is provided in Table 4. 3.5 MOLD The scope of the pre-demolition survey did not include performing a mold survey. Consequently, no mold sampling was performed. 3.6 NATURALLY OCCURRING ASBESTOS While the hazardous material survey excluded testing soil for Naturally Occurring Asbestos (NOA), soil testing for NOA was performed by the project geotechnical consultant. Based on a review of NOA soil testing results provided by the project geotechnical consultant, NOA was not detected in the soils expected to be disturbed during construction of the new building. A full NOA assessment is included in the geotechnical investigation report.

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4.0 REGULATORY CONSIDERATIONS 4.1 Hazardous Material Work - Regulatory Notifications The following notifications will need to be prepared and submitted (where checked):

• Asbestos

☒ Bay Area Air Quality Management District – Form 1102 Demolition Notification

(Demolition only)

☒ Bay Area Air Quality Management District – Form 1102 Demolition Notification

(Asbestos Abatement)

☒ CAL/OSHA – Form 183B Temporary Worksite Notification for Asbestos Related

Work

• Lead

☒ CAL/OSHA – Lead Pre-Work Notification

☒ CDPH – Form 8551 Abatement of Lead Hazards Notification

• Waste Management

☒ City of Piedmont – C&D Waste Management Plan

The above notifications are in addition to the standard construction and workplace notifications required at construction sites by CAL/OSHA and other regulatory agencies. 4.2 Worker Protection and Waste Definitions for Asbestos The state of California has specific regulations regarding asbestos. California standards for the workplace are issued primarily by the California DOSH. Specific asbestos requirements are contained in Title 8 CCR Sections 1529 and 5208. The asbestos standard in Section 1529 applies to asbestos-related construction work, such as routine building maintenance, asbestos removal, renovation, demolition, excavation which may involve exposure to asbestos as a natural constituent, and asbestos spill/emergency cleanup. The asbestos standard in Section 5208 applies to general industry. These standards mandate an 8-hour Time-Weighted Average (TWA) Permissible Exposure Limit of 0.1 fibers/cubic centimeter (f/cc), and a 30-minute excursion limit of 1 f/cc. Employers conducting any operation involving the disturbance of materials containing asbestos and/or which may reasonably be expected to result in employee exposure above the action level and/or excursion limit must register with DOSH using the "Carcinogen Report of Use Form." This is a one-time registration; however, the employer must update the report and provide it to DOSH when there are any changes in report information.

Construction materials containing asbestos greater than 1 (>1%) percent are defined as an ACM and are regulated under both federal and state regulations. Constructing materials containing asbestos greater than 0.1% are defined as an Asbestos Containing Construction Material (ACCM) and are regulated by the State of California. CAL OSHA regulates the removal of both ACM and ACCM.

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Please refer to Title 8 CCR 1529-Asbestos for the regulatory requirements associated with working with both ACM and ACCM. Additionally, refer to 8 CCR 1529(r)-Report of Use and Asbestos-related Work Registration for the DOSH registration requirement of contractors involved in asbestos-related work involving over 100 square feet of ACCM/ACM. In instances where a material contains asbestos in concentrations below the ACCM regulatory threshold (e.g. greater than 0% but less than or equal to 0.1%), the employer is required to comply with CAL OSHA 5194-Hazard Communication in addition to pertinent sections of 8 CCR 1529-Asbestos. The would include the used of HEPA-equipped vacuums, wet methods for removal and prompt cleanup under 8 CCR 1529(g). In California, ACMs that are friable or will become friable during abatement are classified as a California-Hazardous Waste and require special handling, packaging, and disposal. The local air pollution control district regulations should be consulted on how non-friable ACMs are classified for NESHAP purposes and when they are considered to be made friable upon demolition and/or abatement. 4.3 Worker Protection and Waste Definitions of Lead (in paint and construction materials) Title 17 CCR, Division 1, Chapter 8 covers the training, certification and work practices of individuals conducting lead surveys, writing lead work plans, monitoring abatement projects and those engaging in the abatement of LBP in relation to a public or residential building. The regulation also requires notification of abatement be provided five days prior to the start of work and that the notifications be posted at all entrances to the work area. Title 8 CCR Section 1532.1 covers work activities impacting LBP pose a potential exposure risk for workers and/or building occupants. Only workers trained in proper safety and respiratory techniques should perform renovation activities that may impact the LBP described in this report. All construction work where an employee may be occupationally exposed to lead must comply with Cal/OSHA requirements set forth in 8 CCR 1532.1. This regulation requires initial employee exposure monitoring to evaluate worker exposure during work that disturbs lead-containing materials (lead present in detectable levels). Milani & Associates suggests that engineering controls, respiratory protection, and personal protective equipment be employed at the start of any project that could disturb LBP. Other Regulatory Definitions of lead-containing materials are detailed in Title 8 CCR, Title 22 CCR, and Title 40 CFR regulations. CAL OSHA Regulation 8 CCR 1532.1-Lead regulates the removal of materials with detectable levels of lead. Please refer to §1532.1-Lead for the regulatory requirements associated with working with lead-containing materials. It is important to understand that CAL OSHA does not give a regulatory definition of a “lead-containing material”. CAL OSHA and Federal OSHA are concerned with “an employee occupationally exposed to lead”. This is understood to mean material disturbed during construction work containing lead in any amount (i.e., lead-containing paint and lead-based paint) is covered under the lead in construction standard. Additionally, Federal OSHA has determined that the use of XRF data and/or bulk sampling data (e.g., paint chips) are not acceptable for predicting employee exposures to lead. This fact means that contractors cannot use XRF data, paint chip data or bulk sample data as a surrogate for employee exposures during construction work (or the bidding process) as defined in 8 CCR 1532.1(a). The two OSHA interpretation letters below should be reviewed. Again, in summary, they state, the burden of proof is on the employer in regard to employee exposures to lead in construction work and not the reliance on XRF data, bulk sampling data or paint chip sampling data.

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1. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=23455

2. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22701

Current California and Federal regulations do mandate that generators determine if a waste is hazardous or non-hazardous by testing representative samples of the waste. The total lead by Total Threshold Limit Concentration (TTLC), California WET-method Soluble Threshold Limit Concentration (STLC), and Toxicity Characteristic Leaching Procedure (TCLP) analyses should be performed to characterize each waste stream as Federal RCRA hazardous waste, California regulated hazardous waste, non-hazardous waste, or as construction debris. The waste stream must be handled as RCRA hazardous waste if TCLP lead levels exceed 5.0 milligrams per liter (mg/l), or as California-regulate hazardous waste if TTLC lead exceeds 1,000 milligrams per kilogram (mg/kg), and/or STLC lead exceeds 5.0 mg/L, respectively. By calculation, if a sample analyzed for lead by TTLC is found to contain less than 50 mg/kg, then the waste stream represented by the sample result is non-hazardous (a completely soluble waste at this concentration would produce a TCLP lead concentration of less than 5.0 mg/L). Similarly, total lead less than 50 mg/kg will generally produce an STLC lead concentration of less than 5.0 mg/L. The demolition contractor will need to determine if additional waste streams will require waste characterization and testing for proper disposal.

4.4 Worker Protection for Respirable Silica

Demolition and renovation activities that involve work on building components or materials containing silica and

concrete can potentially result in worker exposure to respirable silica dust particles. Employers must comply with

the requirements in 8 CCR 1530.1 to control employee exposures to dust created by operations conducted on

concrete or masonry materials

The revised silica standard that was published on March 25, 2016, and became effective in September 2017 for

occupational exposure to silica. Exposure to respirable silica is regulated by both OSHA and Cal/OSHA. Under

the newly implemented silica standard, the Permissible Exposure Limit (PEL) for crystalline silica was reduced to

50 µg/m3 (micrograms per cubic meter of air) with an action limit of 25 µg/m3. In California, exposure to

respirable silica is regulated by CAL/OSHA under 8 CCR Title 1532.3. The regulation applies to all occupational

exposures to respirable crystalline silica in construction work, except where employee exposure will remain

below 25 micrograms per cubic meter of air (25 µg/m3) as an 8-hour time-weighted average (TWA) under any

foreseeable conditions.

Employers will be required to monitor crystalline silica exposure if workplace levels may exceed 25 µg/m3 for at least 30 days in a year and provide medical monitoring to employees in those workplaces. In the case of construction workers, medical monitoring is required only if the new standards require workers to wear respirators for at least 30 days in a year. Construction industry employers are exempt from the PEL and exposure monitoring requirements if they comply with the engineering controls and work practices specified in the new standards. Specific engineering controls and work practices are identified in Table 1 of the standard.

4.5 Construction and Demolition Debris Management

To encourage Construction & Demolition (C&D) Debris C&D recycling, the city of Piedmont adopted a C&D recycling ordinance in February 2007. The ordinance requires projects within the city, where the total construction costs are projected to be greater than, or equal to $50,000 to divert 50% of their job debris from the landfill. The project applicant is required to submit the following prior to the start of construction:

• A completed and signed Debris Recycling Statement (DRS) prior to the issuance of a building permit.

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• A completed Construction and Debris Waste Reduction and Recycling Plan (WRRP)

• A completed Construction and Demolition Debris Salvaged Materials Form (SMF)

Prior to the start of construction/demolition, the project applicant will also be required to submit a Drop Box – Dumpster Application. Richmond Sanitary Service has an exclusive franchise for the removal of solid waste and recyclable material from properties within the City of Piedmont limits. Richmond Sanitary Service, the City’s franchised waste hauler, will work with the project applicant to ensure that at least 50% of the debris generated is recycled. Richmond Sanitary Service will verify that the contents of the drop box were recyclable and recycled and submit to the City an accounting of the weight and types of materials diverted. Additional information is available at the following link: http://www.ci.piedmont.ca.us/publicworks/c-d-recycling.shtml Copies of the above referenced forms are included in Appendix E.

4.6 Other Applicable Regulations

The following regulations will apply to contractors performing work and building owners that contract with licensed contractors to perform renovation and/or demolition work.

4.6.1 California Health and Safety Code (Cal H&SC) On January 1, 1989, Assembly Bill 3713 mandated the addition to the California Health and Safety Code of Chapter 10.4, which affects owners of buildings constructed prior to 1979. The regulation details notification requirements for owners of buildings with known ACMs and/or ACCMs. The bill requires owners to provide written notices to employees, contractors, and lessees concerning matters related to ACM and ACCM. The notice must include (1) the existence of, the conclusions from, and the contents of asbestos building surveys, (2) specific locations of ACM and ACCM, (3) general procedures and handling restrictions to minimize asbestos disturbance, (4) results of any bulk analysis of air monitoring conducted, and (5) potential health risks associated with asbestos exposure.

For non-friable materials (i.e., material in which asbestos fibers are completely encapsulated), such as asbestos-containing resilient floor covering, notice must include (1) information described in Items 1and 2 in the preceding paragraph, and (2) warning that activities such as removing, sanding, scraping, etc. are restricted and should not be performed by unqualified employees. Notice in writing to each individual employee must be provided within 15 days of the receipt of information identifying the presence or location of ACM and ACCM within the building; annual notification is required thereafter. The regulation also requires the posting of warning notices in building areas where construction, maintenance, or remodeling may create a release or disturbance of ACM and ACCM.

4.6.2 Proposition 65 Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986 took effect August 11, 2003, and is contained in the California Environmental Protection Agency (Cal/EPA) regulations, Title 27 CCR Division 2. This act states that no person in the course of doing business shall knowingly discharge or release a chemical known to the state to cause cancer or reproductive toxicity into water or onto land where such chemical passes or probably will pass into any source of drinking water, notwithstanding any other provision or authorization of law except as provided in Section 25249.9 of the regulation Asbestos was listed on the Proposition 65 list of

http://www.ci.piedmont.ca.us/publicworks/c-d-recycling.shtml

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known carcinogens on February 27, 1987. Businesses are required to provide a "clear and reasonable" warning before knowingly and intentionally exposing anyone to a listed chemical. For asbestos, the level at which warning requirements are exempted, or the "no significant risk level" (NSRL) is 100 fibers inhaled per day or 140 million fibers ingested per day. The 100 fiber NSRL equates to an airborne fiber concentration of 0.00001 f/cc based on the inhalation of 10 cubic meters of air during an 8-hour workday. There are currently no validated sampling and analytical methods capable of detecting airborne fibers at this low level. For practical purposes, the Health and Welfare Agency has indicated that warnings must be posted when indoor airborne asbestos concentrations are significantly higher than ambient (outdoor) levels.

4.6.3 Hazardous Waste Criteria Wastes generated as part of a building renovation or demolition are required to be properly characterized and profiled prior to disposal in accordance with the California Environmental Protection Agency (Cal/EPA) regulations contained in Title 22 CCR. In California, friable asbestos-containing waste, containing more than or equal to 1% (≥ 1%) asbestos must be handled, transported, and disposed of as California regulated hazardous waste in accordance with the California Environmental Protection Agency (Cal/EPA) regulations contained in Title 22 CCR. Asbestos waste containing asbestos greater than 1% must also be disposed under the federal NESHAP regulation as Regulated Asbestos Containing Material (RACM – friable asbestos) In California, lead-containing waste that contains lead at concentrations more than or equal to 1000 mg/kg (1,000 ppm) [TTLC] or more than 5 mg/L soluble lead by the California Waste Extraction Test [WET] must be handled, transported, and disposed of as Non-RCRA California regulated hazardous waste - lead in accordance with the California Environmental Protection Agency (Cal/EPA) regulations contained in Title 22 CCR. Where the soluble lead exceeds 5 mg/L by the federal Toxic Characteristic Leaching Procedure [TCLP], the waste must be handled, transported and disposed of as a RCRA hazardous waste – lead. Hazardous waste must be transported under a Uniform Hazardous Waste Manifest. Friable asbestos waste (RACM) must also be shipped under an EPA Waste Shipment Record. A Uniform Hazardous Waste Manifest can be made equivalent to an EPA Waste Ship Record by the addition of the following information: Amount of asbestos waste in cubic yards and Name and address of administrative agency (local air district). This information must be included in the comment section of the HW manifest. Hazardous wastes must be properly labeled. Hazardous Waste labels must conform to the following requirements: California Hazardous Waste Labels: Asbestos waste streams must be labeled with a hazardous waste label that meets the requirements in 22 CCR 66262.34 (e) and (f). When the waste stream is shipped across the public road, containers must have a label that meets 22 CCR 66262.32. Federal NESHAP Labels: Asbestos waste streams must be marked with signs that meet the OSHA hazards communication labeling requirements while in storage, and when being transported or disposed of to a permitted NESHAP Landfill.

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5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 ACM AND ACCM To comply with NESHAP and PUSD requirements, the following asbestos-containing materials (ACMs) and asbestos-containing construction materials (ACCM) will need to be removed prior to demolition of the building:

• Resilient Floor Tile (RFT): RFT (gray-brown with black mastic, 5% Chrysotile) is present in the Janitor Closet (entire floor) and in the North Storeroom (approximate 80% of floor area). The estimated quantity is 110 square feet. The RFT shall be fully removed and disposed of as a Category I NF ACM where removed using manual methods. Where removed using mechanical methods, the RFT shall be handled, packed and transported as RACM (Friable Asbestos, California Hazardous Waste). The removal of the RFT will be coordinated with the removal of the ACCM drywall to minimize the number of containments to be constructed. OSHA Class II work practices shall be utilized.

• Sink with Soundproof Coating: One sink was identified as containing a soundproof undercoat. The sink is in the Work Room in the administration section of the building. The underside of the sink contains an ACM soundproof coating (black, 3% Chrysotile). The sink shall be removed intact using manual methods and OSHA Class II work practices and disposed of as a Category I NF ACM.

• Interior and Exterior Fire-Rated Doors (Suspect ACM core): The interior hallway doors and exterior doors are suspected of containing an ACM core. The number of suspect interior fire doors was estimated to be nineteen (19) with seven (7) suspect exterior fire doors. Prior to the start of abatement, suspect ACM fire doors shall be inspected to determine if they contain asbestos. This would be accomplished by drilling. Doors determined not to contain asbestos can be left in place or salvaged. Doors determined to contain asbestos will need to be removed, handled, packaged and disposed of as RACM (friable asbestos). Friable asbestos is regulated as a hazardous waste in California. This will require transporting the RACM to a NESHAP permitted landfill under a hazardous waste manifest (RACM – Friable Asbestos, California Hazardous Waste).

• Under Slab Vapor Barrier (Suspect ACM): No original construct drawings were available at the time the pre-demolition survey was performed. An under-slab vapor barrier is suspected to be present below the concrete slab on grade floor. Prior to the start of abatement, the concrete slab on grade floor should be cored at a minimum of two (2) locations to determine if an under-slab vapor barrier is present. Where a vapor barrier is observed, the vapor barrier should be sampled and analyzed for asbestos. The vapor barrier is anticipated to cover the full building footprint. The building footprint is estimated to be approximately 12,600 square feet. Where the vapor barrier is found to contain asbestos, demolition practices will be implemented to maintain the vapor barrier in an intact condition while it is being exposed and removed. The vapor barrier shall be removed, handled, packaged and disposed of a CAT I NF ACM.

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• Drywall Joint Compound (ACCM): The existing drywall system, except for the counseling office renovation area (former Classroom 18), was determined to be an ACCM (<0.25% to 0.5% Chrysotile). PUSD will require that the ACCM drywall system be removed prior to demolition of the building. Based on the building layout, an estimated 16,000 square feet of drywall is present. The drywall will be removed by putting the entire building within a Negative Pressure Enclosure (NPE). OSHA Class II work practices will also be utilized.

• Blackboard Shim Tile: Based on a previous classroom renovation, the original slate blackboards are anticipated to have shim tiles glued to the backside of the blackboard. Individual shim tiles are glued together to form a stack. The shim tiles are classified as ACCM (<25% Chrysotile). There is one original blackboard in each classroom. Assuming 8 blackboards, the quantity of blackboard shim tile was estimated to be approximately 45 square feet. PUSD will require that the ACCM shim tiles be removed prior to demolition of the building. The removal of the ACCM shim tile should be coordinated with the removal of the ACCM drywall. OSHA Class II work practices will also be utilized.

• Regulatory Requirements: Since the quantity of the ACM is greater than 100 square feet, the removal of the ACM will require the contractor to have DOSH registration as an asbestos abatement contractor for removal of the ACM. The contractor will also need to be a California licensed asbestos contractor2 and use asbestos trained workers and supervisor to remove the ACMs and ACCMs. During removal of the ACMs and ACCMs, work practices and regulatory notifications identified in the OSHA Asbestos in Construction Standard [CAL OSHA 1529] and BAAQMD Regulation 11, Rule 2 will need to be implemented by the asbestos abatement contractor. This will require the use of containment (NPE), regulated areas, wet methods, prompt cleanup of the ACM, placement in a leak-proof container, and perimeter air monitoring. If the contractor does not have a negative exposure assessment, contractor employee’s will need to set up a regulated area and wear appropriate PPE, including respiratory protection. The ACMs identified as RACM will need to be removed, handled, packaged and disposed of in conformance with the requirements identified in CAL/OSHA 1529. RACM will need to be transported under a Uniform Hazardous Waste Manifest as Friable Asbestos and EPA Waste Shipment Record. Category I non-friable ACM can be disposed of as Non-hazardous asbestos-containing waste under a non-hazardous waste manifest.

• Demolition of the building will be subject to Federal National Emission Standards for Hazardous Air Pollutants (NESHAP). Materials identified as ACM will need to be removed from the building prior to demolition. All ACM and ACCM removal will be performed within a regulated area including a Negative Pressure Enclosure (NPE).

• Removal of Regulated Asbestos Containing Materials (RACM) greater than 100 square feet will require notification to BAAQMD to obtain a J number. In addition, demolition of the building is also subject to a NESHAP demolition permitting. NESHAP demolition permitting

2 California C-22 specialty license or California Contractor License (Class A or B) and asbestos certification pursuant to Section 7058.5 of the California Business and Professions Code (BPC).

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will require notification to the BAAQMD for the demolition of the building by completing BAAQMD Form 1102 (Demolition Notification).

5.2 LEAD All lead in construction-related work shall be performed in conformance with OSHA Lead in Construction Standard [CAL OSHA 1532.1]. Building components and paint coating system found to contain lead will be handled as follows:

• Vent Pipe Flashing: The lead sheet vent pipe flashing at all five (5) roof vent pipe locations shall be removed. Since the flashing consist of lead sheeting, the lead sheeting should be recycled.

• Demolition Waste Streams- No Additional Characterization: The following lead-containing waste streams were determined not to require additional waste characterization and can remain in the building unless specified elsewhere to be removed as apart of asbestos abatement, for recycling and/or reclamation or salvaged for reuse by the PUSD:

▪ Interior Painted Wood Trim, Door, and Door Casing Paint - All painted wood wall trim, wood doors and wood door casings located in the interior of the building. Wood doors classified as fire doors are to be removed and handled a RACM.

▪ Interior Metal Lockers and Metal Door Systems - All painted metal lockers (hallways), metal doors and metal door frames in the interior of the building. Metal doors classified as fire doors are to be removed and handled a RACM.

▪ Exterior Metal Door and Window Systems - All metal doors and metal door frames on the exterior of the building. Metal doors classified as fire doors are to be removed and handled a RACM.

▪ Ceramic Tile Wall Systems – Green ceramic wall tile and brown ceramic floor tile in exterior accessed restrooms

▪ Exterior Painted Wood Window Casing – All painted wood surround casing on the exterior of the building.

• Demolition Waste Streams- Additional Characterization Required: The following demolition waste streams were determined to need additional waste characterization to establish removal and disposal requirements:

▪ Waste Stream WS-1: White Pebble Texture Coat over concrete substrate – Interior column faces on all sixteen (16) columns located along exterior walls of the building.

▪ Waste Stream WS-2: White Pebble Texture Coat over concrete substrate – Exterior faces of columns on the building (sixteen columns) and all exterior columns that support the wood Trellis/Portico structure (thirteen columns).

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▪ Waste Stream WS-3: White Stucco Texture Coat over concrete substrate – on exterior building wall faces.

The demolition waste streams WS-1, WS-2, WS-3 will need to be tested for total lead (TTLC) and soluble lead (WET and TCLP) to determine if the components will need to be disposed of as Construction Debris, Non-RCRA California Regulated HW - Lead or RCRA Hazardous Waste – lead. The lead waste characterization procedure is shown in Figure 6.

• Demolition Waste Stream Sampling Methods: The specific method for sampling procedure for waste streams WS-1, WS-2, WS-3 will depend on if the concrete will be recycled or if the concrete will be disposed of to a Class II/III landfill. The specific sampling methods include the following methods:

▪ Method #1 – Concrete is Recycled: Based on discussion with local concrete recyclers, concrete to be recycled must be free of all paint coating systems that contain lead. This will require removal of the paint coating systems from the following building components and/or waste stream:

➢ Waste Stream #1: Building Columns (interior column faces) – The white pebble texture paint coating is present on the interior column faces of all columns located around the perimeter of the building. Based on the site drawing, there are a total of sixteen (16) columns. The texture coat is applied to interior surfaces of the concrete columns for the full interior room height. The interior column faces are estimated to contain approximately 650 square feet of the white pebble texture paint coating.

➢ Waste Stream #2: Building Columns (exterior faces) and Trellis/Portico Structure Columns: The white pebble texture paint coating is present on the exterior faces of all the building columns and on all the columns that support the trellis/portico structure. Based on the site drawing, there are a total of sixteen (16) building columns and thirteen (13) trellis/portico structure columns. The texture coat is applied to the full height of the columns. The exterior building column faces and the trellis/portico structure columns are estimated to contain approximately 2,250 square feet of the white pebble texture paint coating.

➢ Waste Stream #3: Exterior Building Walls: A white texture stucco coat is present on the exterior face of all exterior walls. The exterior walls are estimated contain approximately 5,400 square feet of the white texture stucco coat.

The individual waste streams will need to be kept separate for waste characterization purposes. Representative bulk samples from each waste stream will need to be collected. The sampling of each waste stream should follow procedures detailed in EPA SW-846. This will require collecting between three and six representative samples. Samples should be analyzed for total lead and soluble lead as shown in Figure 6.

▪ Method #2 – Concrete is Not Recycled: Where painted concrete will not be recycled, the demolition contractor will need to determine if additional waste characterization will be

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necessary to establish a waste profile for the concrete scheduled for disposal. Where determined to be necessary, representative samples will need to be collected. This would require collecting full-depth samples using concrete coring methods.

5.3 ORMs and Universal Wastes

Other Regulated Materials (ORMs) and Universal wastes that are present in the building will need to be removed. Handling and disposal of each material is discussed below

• Mercury-containing fluorescent lights (tubes and CFLs), Thermostats, Thermometers, and Switches: Mercury-containing ORMs identified in the building will need to be removed prior to demolition of the building and disposed of in conformance with applicable laws and regulations. These include mercury-containing fluorescent lights (tubes and CFLs), thermostats, thermometers, and switches. A total of two hundred forty-eight (248) fluorescent light fixtures were observed. Each light fixture is assumed to contain four tubes.

• PCB-containing Light Ballasts: PCB-containing ORMs identified in the building will need to be removed prior to demolition of the building and disposed of in conformance with applicable laws and regulations. These include PCB-containing light ballasts. The total quantity of ballasts was estimated to be two hundred forty-eight (248) based on the observed quantity of fluorescent light fixtures.

• Ozone Depleting Chemicals: There are four (4) roof-mounted HVAC package units. Each HVAC package unit is anticipated to contain oil and refrigerant. These chemicals are considered ozone-depleting chemicals. The oil and refrigerant shall be removed and be recycled by an EPA-certified HVAC technician.

• Low-level radioactive or Electronic Components: Smoke detectors were identified as part of the fire alarm system in the building. All smoke detectors are to be removed prior to building demolition. The locations of the smoke detectors are shown the fire alarm plan for the building (See Appendix C). The smoke detectors may contain either low-level radioactive or electronic components that will require recycling or special disposal. Heat detectors and other fire alarm components were identified as part of the fire alarm system in the building. All heat detectors and other fire alarm components are to be removed prior to building demolition. The locations of the heat detectors are shown the fire alarm plan for the building (See Appendix C). The heat detectors and other fire alarm components may contain electronic components that will require recycling or special disposal.

• Pressure Treated Wood/Treated Wood Waste: PUSD will not reclaim the pressure treated wood in Trellis/Portico structure or the building window trellis sun shade. All pressure treated wood will need to be handled and disposed of as Treated Wood Waste (TWW) under the alternative management standards (AMS) under California Code of Regulations, Title 22, Division 4.5, Chapter 34. This will require disposal to Class II/III landfill permitted to receive TWW.

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5.4 ADDITIONAL CONSIDERATIONS - CONCRETE

A January 2014 EPA Regulatory Determination in response to a letter from the California Air Resources Board determined that concrete should be considered as a suspect ACM. The determination applies to heavy concrete structures, boiler housekeeping pad, and similar structures. In addition, subsequent EPA guidance has stated that where more than 160 square feet of concrete will be demolished and recycled, the concrete should be tested for asbestos. At present, BAAQMD is recommending that concrete that is scheduled to be recycled should be tested for asbestos. Local concrete recyclers that were contacted also indicated that they do not require asbestos testing documentation. However, some local landfills have begun requiring documentation that the concrete has been tested for asbestos and requiring concrete with regulated levels of asbestos (asbestos content greater than 1%) to be properly packaged and transported in conformance with NESHAP and CAL/OSHA regulations. Based on the above, a supplemental survey was conducted. The concrete foundation system was sampled and was found not to contain asbestos. However, the general and/or demolition contractor may need to perform additional sampling of concrete where required by concrete recyclers or by Class II/III landfills for waste profiling and acceptance.

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6.0 LIMITING CONDITIONS Milani & Associates conducted the pre-demolition hazmat survey on July 13, 2017, in general accordance with industry standards for bulk asbestos sampling, bulk lead sampling and lead XRF procedures in existence at the time of the project. A supplemental survey was conducted on May 10, 2018 specifically for sampling the concrete foundation system of the building. Bulk sampling of the concrete was performed in accordance with industry standards for concrete bulk sampling in existence at the time the sampling was performed. The conclusions and recommendations presented in this report are based on the applicable standards of our profession at the time this report was prepared. Copies of this report are furnished to provide the factual data that were gathered and summarized in the report. The analysis and recommendations submitted in this report are based in part on the data obtained from specific and discrete, representative sampling locations throughout the interior wall, floor and ceiling systems as well as exterior and roof systems. However, the nature and extent of variations between the sampling locations may not become evident until planned renovation and/or demolition procedures commence. If potential variations are identified during renovation or demolition activities, it may be necessary to conduct additional bulk sampling. The general and/or demolition contractor may need to perform additional sampling of concrete where required by concrete recyclers or by Class II/III landfills for waste profiling and acceptance. This report has been prepared for the exclusive use of Piedmont Unified School District for specific application to the locations where the survey was performed. This report may not be copied, except by Piedmont Unified School District, without the express written permission of Milani & Associates. No other representation, expressed or implied, is made.

FIGURES

PIEDMONT HIGH SCHOOL

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MILANI

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Concord, CA 94520

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2655 Stanwell Drive, Suite 105

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CLASSROOM 17

CLASSROOM 16 CLASSROOM 15

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SOCIAL SCIENCEDEPT. OFFICE WORK ROOM CONF. ROOM LANGUAGE

DEPT. OFFICE

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MAIL ROOMCOMMUN.

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090820-XXX AND 090820-XXXL SAMPLE

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ASSOCIATES FIRE ALARM SURVEY REPORT

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(2009)

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180510-101

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TAKEN BY MILANI AND ASSOCIATES

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EACH AC UNIT HAS ELECTRIC AND GAS

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HW - LEAD

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TABLES

Sample ID6 Homogenous

Sample GroupMaterial Description Material Location Condition Substrate Layer Asbestos Status

AHERA/OSHA

Category1,8

NESHAP

Category2,8

Cal/OSHA

Class of Work4

Quantity on-site

(sf or lf)Comments 9

g wood drywall ND ----- ----- ----- ----- -----

g drywall tape ND ----- ----- ----- ----- -----

g drywall joint compound2% Chrysotile (PLM, std)

<0.25% (PLM 400 Pt Ct) ACCM ----- -----

Approximately

16,000-16,200

sq.ft. for all

ACCM Drywall

1. All ACCM to be removed

prior to demolilition.

2. Dispose of as non-

hazardous asbestos-

containing construction

waste

g wood drywall ND ----- ----- ----- ----- -----

g drywall tape ND ----- ----- ----- ----- -----


<0.25% (PLM 400 Pt Ct) ACCM ----- -----

Approximately

16,000-16,200

sq,ft,for all

ACCM Drywall




hazardous asbestos-


waste

g wood drywall ND ----- ----- ----- ----- -----

g drywall tape ND ----- ----- ----- ----- -----


<0.25% (PLM 400 Pt Ct) ACCM ----- -----

Approximately

16,000-16,200

sq.ft. for all

ACCM Drywall




hazardous asbestos-


waste

g wood drywall ND ----- ----- ----- ----- -----

g drywall tape ND ----- ----- ----- ----- -----


<0.25% (PLM 400 Pt Ct) ACCM ----- -----

Approximately

16,000-16,200

sq.ft.for all

ACCM Drywall




hazardous asbestos-


waste

Table 1A

Piedmont High School - Administration Building (Building D) Demolition

Asbestos Bulk Sample Analytical Summary - Administration Building Interior

August 20, 2009 - Millenium Fire Alarm Survey Samples

800 Magnolia Avenue, Piedmont, CA

090820-905 -----

090820-906

090820-907

-----

-----

DWS, white

DWS, white

DWS, white

Admin Bldg (Building D),

Outside Counseling Office

[East Hallway, North Wall]


Inside Room 12

[North Wall, NE Corner]


Inside Room 16

[South Wall]

Admin Bldg (Building D0,

Inside Room 13

[North Wall, NE Corner]

090820-908 ----- DWS, white

T-1



AHERA/OSHA

Category1,8

NESHAP

Category2,8

Cal/OSHA

Class of Work4

Quantity on-site


Table 1A





161130-101 1 Blackboard Mastic, yellow Classroom 12 Gray Black Slate Mastic ND N/A N/A N/A

161130-102 1 Blackboard Mastic, yellow Classroom 12 Gray Black Slate Mastic ND N/A N/A N/A

161130-103 2Blackboard Shim Tile, light gray

with black streaksClassroom 12

Yellow Mastic/

Gray Black SlateShim Tile

<1% Chrysotile - PLM

<0.25 Chrysotile - PLM, 400 pt ctACCM ----- -----

Approximately

40-45 sq.ft.




hazardous asbestos-


waste

170713-15Mortar bed, lt. gray, under

brown tile

Bldg D, Mens RR, H/C Stall,

NE Cornerg concrete mortar ND ----- ----- ----- ----- -----


green tile

Bldg D, Mens RR, H/C Stall,

NE Cornerg concrete mortar ND ----- ----- ----- ----- -----

170713-17 grout, brown off of brown tileBldg D, Mens RR, H/C Stall,

NE Cornerg mortar grout ND ----- ----- ----- ----- -----

170713-18 grout, gray off of green tileBldg D, Mens RR, H/C Stall,


170713-19 grout, gray off of green tileBldg D, Mens RR, H/C Stall,


170713-20 grout, brown off of brown tileBldg D, Mens RR, H/C Stall,



green tile

Bldg D, Womens RR, NW

Cornerg concrete mortar ND ----- ----- ----- ----- -----


brown tile

Bldg D, Womens RR, NW

Cornerg concrete mortar ND ----- ----- ----- ----- -----

g mastic carpet ND ----- ----- ----- ----- -----

g concrete mastic ND ----- ----- ----- ----- -----

g mastic cove base ND ----- ----- ----- ----- -----

g drywall mastic ND ----- ----- ----- ----- -----





170713-25 12Carpet, brown with black

spots and yellow masticBldg D, office #1, NE corner

Bldg D, office #1, NE cornerCove base, tan, with white

mastic13170713-26

July 14, 2017

8

9

8

170713-23 10 gray Carpet with yellow masticBldg D, Mens RR,

NE Corner at door

170713-24 11Cove base, black 6", with

white yellow mastic

Bldg D, Faculty RR Waiting

Room, center North wall

November 30, 2016

T-2



AHERA/OSHA

Category1,8

NESHAP

Category2,8

Cal/OSHA

Class of Work4

Quantity on-site


Table 1A





g wood drywall ND ----- ----- ----- ----- -----

g joint compound tape ND ----- ----- ----- ----- -----

g drywall joint compound ND ----- ----- ----- ----- -----

170713-28Dry Wall System (DWS), Tan,

field

Bldg D, office #1,

North wallg wood drywall ND ----- ----- ----- ----- -----





170713-31LCT, white with random

holes and channels

Bldg D, Office #1 ceiling,

West centerg phlenum LCT ND ----- ----- ----- ----- -----

170713-32LCT, white with random

holes and channels

Bldg D, Office #4 ceiling, SW

cornerg phlenum LCT ND ----- ----- ----- ----- -----

170713-33Column Texture, white pebble

textureBldg D, Office #4, NE corner g concrete Column Texture ND ----- ----- ----- ----- -----

170713034Column Texture, white pebble

textureBldg D, Office #5, SE corner g concrete Column Texture ND ----- ----- ----- ----- -----

g mastic RFT <1% - Chrysotile (PLM, Std)

400 Pt Ct not

requested for RFT,

Mastic is ACM

g concrete mastic 5% - Chrysotile (PLM, Std) ACM

g mastic RFT <1% - Chrysotile (PLM, Std)

400 Pt Ct not

requested for RFT,

Mastic is ACM

g concrete mastic Positive Stop, (Not Analyzed) ACM

g mastic RFT ND ----- ----- ----- ----- -----


170713-38 19 Sink Sound Proofing, BlackBldg D, workroom, South

wall, centerg metal soundproofing 3% - Chrysotile (PLM, Std) ACM CAT I NF Class II 4 sq.ft.

Dispose of as CAT I Non-

Friable ACM.



Cove base, tan, with white

mastic

170713-30 12

170713-37 18

RFT, gray brown with white

and brown striations, yellow

mastic

170713-27

14

Dry Wall System (DWS), Tan,

with tape and joint

compound, corner

1. Dispose of as CAT I Non-

Friable ACM.

2. Reclassify as RACM and

dispose of as California

Regulated Hazardous

Waste - Friable Asbestos if

mechanical methods are

used to remove RFT and

Mastic.

CAT I NF Class II 53 sq. ft.

CAT I NF Class II 55 sq.ft.

Bldg D, office #1, NW corner

Bldg D, office #1, NE corner

170713-29 Bldg D, office #1, NE corner13

RFT, gray brown striations,

black mastic

RFT, gray brown striations,

black mastic

Bldg D, Janitor Closet, SE

corner

Bldg D, North Storage

Room, SW corner

Bldg D, North Storage Room,

SW corner

170713-39 20Carpet tile, blue gray with

yellow mastic

Bldg D, South floor,

workroom, at door

15

16

170713-36

170713-35

17

Carpet, brown with black

spots and yellow mastic

T-3



AHERA/OSHA

Category1,8

NESHAP

Category2,8

Cal/OSHA

Class of Work4

Quantity on-site


Table 1A





g wood drywall ND ----- ----- ----- ----- -----


g drywall joint compound<1% - Chrysotile (PLM, Std)

0.25% Chrysotile (PLM 400 Pt Ct)ACCM ----- -----

Approximately

16,000-16,200

sq.ft. for all

ACCM Drywall




hazardous asbestos-


waste


g compound mastic ND ----- ----- ----- ----- -----

g drywall compound<1% Chrysotile (PLM Std)

0.50% Chrysotile (PLM 400 Pt Ct)ACCM ----- -----

Approximately

16,000-16,200

sq.ft. for all

ACCM Drywall




hazardous asbestos-


waste

g mastic carpet ND ----- ----- ----- -----


g wood drywall ND ----- ----- ----- ----- -----


g drywall joint compound2% Chrysotile (PLM, Std)

<0.25% Chrysotile (PLM 400 Pt Ct)ACCM ----- ----- -----




hazardous asbestos-


waste

Bldg D, workroom, E. wall,

S corner

11170713-41

170713-43 22

21170713-40DWS, yellow white with

tape and joint compound

DWS, white, with tape and

joint compound

Bldg D, Admin Reception,

NE corner

Covebase, black 6", with

yellow mastic

Bldg D, workroom, East

wall, South corner

20170713-42Carpet, blue gray with yellow

mastic

Bldg D, Admin Reception,

NE corner

T-4



AHERA/OSHA

Category1,8

NESHAP

Category2,8

Cal/OSHA

Class of Work4

Quantity on-site


Table 1A





g mastic covebase ND ----- ----- ----- ----- -----


g drywall compound2% Chrysotile (PLM, Std)

<0.25% Chrysotile (PLM 400 Pt Ct)ACCM -----

Approximately

16,000-16,200

sq.ft. for all

ACCM Drywall




hazardous asbestos-


waste



170713-46 16 Column texture, white Bldg D, Room 16 NE Corner g concrete column texture ND ----- ----- ----- ----- -----



g drywall compound<1% Chrysotile (PLM, Std)

0.25% Chrysotile (PLM 400 Pt Ct) ACCM CAT I NF

Approximately

16,000-16,200

sq.ft. for all

ACCM Drywall




hazardous asbestos-


waste

g mastic RFT ND ----- ----- ----- ----- -----


g mastic RFT ND ----- ----- ----- ----- -----




Notes:

5. ND = No asbestos detected in sample

6. Note: Items not in numerical order have been grouped and sorted by homogeneous material

7. DWS = Drywall System. System includes drywall, tape, and joint compound/taping mud

8. Texture Coat (TC) - Classified as an add-on coating by OSHA. Not classfied as an AHERA surfacing material.

9. Unless specified for removal, material can remain in place during demolition

11. H/C = Handicapped Stall

12. RR = Restroom

Carpet, blue, yellow, white

pebble pattern with yellow

mastic

Bldg D, Room 16 NE Corner

10. All bulk samples collected by Milani and Associates except where noted in table. Bulk samples by others were used as reported.

4. OSHA Class of Work - Applies to removal and/or disturbance of buidling materials with >1% asbestos content (Class I, Class II, Class III, Class IV). OSHA regulates removal of all materials that contain asbestos greater that 0% under Title 8 CCR 1529.

2. NESHAP Category - For Renovation and/or Demolition identification for Category I Non-Friable [CAT I], Category II Non-Friable [CAT II], or friable materials (Regulated ACM [RACM]) with > 1% asbestos content.

3. Asbestos-containing construction material (ACCM)- Building materials with asbestos content > 0.1% but ≤ 1%.

1. AHERA Category - Materials classified as TSI, Surfacing or Miscellaneous

170713-45 24

170713-50 27Covebase, black 4" with

yellow mastic

Bldg D, East Hallway, North

wall, center locker

Bldg D, East Hallway,

SW corner

Bldg D, East Hallway,

West wall center

170713-49

26RFT, lt. gray with dark gray

lineations and yellow brown

mastic

Bldg D, North Hallway, South

wall center

170713-47

170713-48

11Cove base, black 6" with

yellow mastic

RFT, lt. gray with dark gray

lineations and yellow brown

mastic

23170713-44Cove base, gray brown with

yellow mastic

Bldg D, Room 16 NE

Corner

T-5

Sample ID6,9 Homogenous


AHERA

Category1,8

NESHAP

Category2,8

Cal/OSHA

Class of Work4

Quantity on-site

(sf or lf)

Comments/

Quantity (sf) 9

Composition Roof g tar Comp. Roof ND ----- ----- ----- ----- -----

Tar g felt tar ND ----- ----- ----- ----- -----

Felt g wood felt ND ----- ----- ----- ----- -----

Composition Roof g tar Comp. Roof ND ----- ----- ----- ----- -----

Tar g felt tar ND ----- ----- ----- ----- -----


Composition Roof A g tar Comp. Roof ND ----- ----- ----- ----- -----

Tar g felt tar ND ----- ----- ----- ----- -----


g tar Comp. Roof ND ----- ----- ----- ----- -----

g felt tar ND ----- ----- ----- ----- -----

g wood felt ND ----- ----- ----- ----- -----

170713-05 Roof Tile Vapor Barrier, black Bldg D, Roof Tile, S.W. center g wood vapor barrier ND ----- ----- ----- ----- -----

170713-06 Roof Tile Vapor Barrier, black Bldg. D, Roof Tile, S.E. center g wood vapor barrier ND ----- ----- ----- ----- -----

170713-07 4 Flashing Mastic, white Trellis Roof, S. edge g metal mastic ND ----- ----- ----- ----- -----

170713-08 Penetration Mastic, Black Trellis Roof, N.E. Corner g metal mastic ND ----- ----- ----- ----- -----

170713-09 Penetration Mastic, Black Trellis Roof, N.W. Corner g metal mastic ND ----- ----- ----- ----- -----

170713-10 Flashing Mastic, grey Bldg D, Roof, N.W. corner g metal mastic ND ----- ----- ----- ----- -----

170713-11 Flashing Mastic, grey Bldg.D, Roof N.E. corner g metal mastic ND ----- ----- ----- ----- -----

170713-12Flashing Mastic, Dark Grey,

Flashing cap on post

Bldg D, Roof, Flashing cap on

post N.E. cornerg wood mastic ND ----- ----- ----- ----- -----


Flashing cap on post

Bldg D, Roof, Flashing cap on

post N.W. cornerg wood mastic ND ----- ----- ----- ----- -----


Water Spigot Sleeve

Bldg D, Roof, N. center under tile

roofg metal mastic ND ----- ----- ----- ----- -----

170713-51 28Exterior Column Stucco,

whiteBldg D, S.W. corner column g concrete stucco ND ----- ---- ----- ----- -----

July 14, 2017

Table 1B



Asbestos Bulk Sample Analytical Summary - Exterior and Roof

Bldg D, Roof A S.W. corner field

Composition Roof A Bldg D, Roof A N.E. corner field

170713-01 1

170713-02 1

Roof B "trellis roof" N.E. Corner

Field

Roof B "trellis roof" N.W. Corner

Field

7

5

6

3

170713-03

170713-04

2

2

T-6

Sample ID6,9 Homogenous


AHERA

Category1,8

NESHAP

Category2,8

Cal/OSHA

Class of Work4

Quantity on-site

(sf or lf)

Comments/

Quantity (sf) 9

July 14, 2017

Table 1B



Asbestos Bulk Sample Analytical Summary - Exterior and Roof

170713-01 1Roof B "trellis roof" N.E. Corner

Field

170713-53 30 Door Caulking, greyBldg D, Exterior, West Hallway

door, West side, lowg metal caulking ND ----- ----- ----- ----- -----

170713-54 31 Stucco, white upper exteriorBldg D, Exterior East Wall, North

center at column 3g concrete stucco ND ----- ----- ----- ----- -----

170713-55 32Spray coating, white on

concrete, lower

Bldg D, Exterior East Wall, North

center at column 3g concrete stucco ND ----- ----- ----- ----- -----

180510-101 33 Concrete, Gray Bldg D Southwest Exterior Door g N/A concrete ND ----- ----- ----- -----no substrate for a concrete

slab

Notes:





9. Unless specified for removal, material can remain in place during demolition

May 10, 2018



3. Asbestos-containing construction material (ACCM)- Building materials with asbestos content > 0.1% but ≤ 1%.4. OSHA Class of Work - Applies to removal and/or disturbance of buidling materials with >1% asbestos content (Class I, Class II, Class III, Class IV). OSHA regulates removal of all materials that contain asbestos greater that 0% under Title 8 CCR 1529.

10. All bulk samples collected by Milani and Associates except where noted in table. Bulk samples by others were used as reported.

T-7


SampleMaterial Description Material Location Condition Substrate Layer Asbestos Status

AHERA

Category1,5

NESHAP

Category2,5

Cal/OSHA Class

of Work3

Quantity on-site (sf

or lf)Comments/Quantity (sf)

8

170713-52 29 Sealant, greyBldg D, Sidewalk Expansion

Joint, SW cornerg concrete sealant ND ----- ----- ----- ----- -----

Notes:


Table 1C


July 14, 2017

800 Magnolia Avenue, Piedmont, CAAsbestos Bulk Sample Analytical Summary - Site





3. Asbestos-containing construction material (ACCM)- Building materials with asbestos content > 0.1% but ≤ 1%.4. OSHA Class of Work - Applies to removal and/or disturbance of buidling materials with >1% asbestos content (Class I, Class II, Class III, Class IV). OSHA regulates removal of all materials that contain asbestos greater that 0% under Title 8 CCR 1529.


T-8

Sample ID Sample Type Material Description Material Location2 Condition Substrate Layer

Lead

Concentration

(ppm)1

Lead

Concentration

(W%)1

Lead ClassifcationQuantity on-site

(sq ft or lf)Comments

090820-904L Paint Chip Paint, Off white

Admin Building (Building D)

outside Counseling Office

[East Hallway, North Wall, NE]

Intact drywall paint <100 <0.0100 Lead-containing N/A

090820-905L Paint Chip Paint, CreamAdmin Building (Building D) Inside

Room 16 [South Wall]Intact drywall paint <100 <0.0100 Lead-containing N/A

090820-906L Paint Chip Paint, CreamAdmin Building (Building D) Inside

Room 13 [North Wall]Intact drywall paint <100 <0.0100 Lead-containing N/A

090820-907L Paint Chip Paint, Off white

Admin Building (Building D)

outside Room 12 [West Hallway,

West Wall, SW Corner]

Intact drywall paint <100 <0.0100 Lead-containing N/A

170713-101L Bulk Ceramic floor tile, brownBldg D, Mens RR floor, H/C stall

NE corner floorIntact mortar ceramic tile 7.3 0.00073 Lead-containing N/A

170713-102L Bulk Ceramic floor tile, brownBldg D, Womens RR floor, NW

corner floorIntact mortar ceramic tile 0.55 0.000055 Lead-containing N/A

170713-103L Bulk Ceramic wall tile, greenBldg D, Mens RR floor, H/C stall

NE corner wallIntact mortar ceramic tile 0.58 0.000058 Lead-containing N/A

170713-104L Bulk Ceramic wall tile, greenBldg D, Womens RR floor, NW

corner wallIntact mortar ceramic tile ND(0.50) ND

Non-Lead

ContainingN/A

Notes:

2. Abbreviations: H/C = Handicapped, RR = Restroom

3. N/A = Not Applicable

1. ND () = No lead detected in sample above method detection limit (mdl). MDL in ( ).

Table 2A




Lead Bulk Sample Analytical Summary

July 13, 2017

No additional lead waste

characterization required.

Remove and dispose of ceramic

tile with building demolition

waste.



Remove and dispose of ceramic

tile with building demolition

waste.



Drywall is ACCM. See Table 1A

for quantity, handling and

disposal.

T-9

Sample ID Material Description Material Location4 Condition Substrate Layer

Total Lead

Concentration

(mg/Kg)2

Total Lead

Concentration

(W%)2

Soluble Lead

Concentration

(mg/L)

Lead Load

(mg/cm2)

Lead ClassifcationQuantity on-site


WS-1 White Pebble Texture Coat Interior Building Column Faces Intact Concrete Paint Coating ----- ----- ----- 0.4 - 1.0 Lead Containing 650 sfFull Waste Characterization required

(Total and Soluble Lead)

WS-2 White Pebble Texture Coat Exterior Building Column Faces

Trellis/Portico Column FacesIntact Concrete Paint Coating ----- ----- ----- 0.5 - 1.0 Lead Containing 2,250 sf

Full Waste Characterization required


WS-3 White Stucco Texture Coat Exterior Building Wall Faces Intact Concrete Paint Coating ----- ----- ----- 0.2 - 1.0 Lead Containing 5,400 sfFull Waste Characterization required


1,000 0.1 ----- -----

----- ----- 5 -----

----- ----- 5 -----

Notes:

1. See Figure 5 for Lead Waste Characterization Sampling and Analysis Procedure.

2. ----- = Analysis not performed or no data available

Table 2B


Lead Bulk Waste Characterization Summary - Building Interior & Exterior

July 13, 2017


Federal TCLP (mg/L)

California TTLC

Regulatory Limits

California STLC (mg/L)

T-10

Component Regulated Material Building Location Description/Note Estimated Quantity1,2,3

Lighting - Fluorescent Light (Tubes) Mercury Bldg D Interior 474 total bulbs, various lenghts 474

Lighting - Compact Fluorescent Light (CFLs) Mercury Bldg D Interior/Exterior None Observed 0

Lighting Ballasts PCBs Bldg D Interior 248 fixtures, 1 ballast per fixutre 248

Pressure Treated Wood (TWW) Pentachlorophenol (TWW) Bldg D Trellis and Sun Shades ExteriorSeparate Pressure Treated wood from non-

pressure treated32,359

Thermostats Mercury Bldg D Interior Contractor to field locate for removal 4

Digital/Electronic Smoke Detector/Fire Alarms Heavy Metals/Electronic Components Bldg D Interior of buildingSee Appendix C for Bldg D Fire Alarm

DrawingContractor to verify

HVAC System - Compressor/Refrigerant Reservoir Hazardous Material - Liquid Bldg D Roof Package HVAC Units 4

3. Quantity of pressure treated wood estimated in board feet. See Table 4 for detail. Contractor to field verify.

2. HVAC unit was unable to be opened. HVAC unit contains compressor oils and/or refrigerants that require capture and/or removal by a certified refrigerant recovery technician.

Notes:

July 14, 2017

Table 3



1. Quantity of fluorescent light tubes and ballasts estimated. Contractor to field verify prior to demolition.

ORMs and Universal Waste

T-11

Component Regulated Material Building Location TWW Board Dimensions Board Feet (per board) Condition Quantity Total Board Feet

Pressure Treated Wood Pentachlorophenol (TWW) Bldg D and C Trellis and Sun Shades Exterior 4" x 16" x 28' 149 Good 29 4,331






Pressure Treated Wood Pentachlorophenol (TWW) Bldg D and C Trellis and Sun Shades Exterior 3" x 10" x 10' 25 Good 16 400


Pressure Treated Wood Pentachlorophenol (TWW) Bldg D and C Trellis and Sun Shades Exterior 2" x 4" x 6' 4 Good 126 504


Pressure Treated Wood Pentachlorophenol (TWW) Bldg D and C Tile Roof Support Structure Exterior Miscellaneous ----- ----- ----- 12,000

32,359

Table 4

Piedmont High School - Building D and C Trellis and Sunshade Demolition


Treated Wood Waste (TWW) Quantity Summary

July 31, 2017

Notes:

1. Quantity and estimated board feet of pressure treated wood are approximate. Contractor to field verify.

TOTAL

T-12

APPENDIX A

CERTIFIED ANALYTICAL REPORTS

EMSL Analytical, Inc.464 McCormick Street San Leandro, CA 94577

Tel/Fax: (510) 895-3675 / (510) 895-3680

http://www.EMSL.com / [email protected]

091714698EMSL Order:

Customer ID: MLAN42

Customer PO: 1048

Project ID:

Attention: Phone:Mark Milani (925) 330-7642

Fax:Milani & Associates

Received Date:2655 Stanwell Drive 07/17/2017 11:45 AM

Analysis Date:Suite 105 07/23/2017 - 07/24/2017

Collected Date:Concord, CA 94520

Project:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

170713-1

091714698-0001

None DetectedMatrix

Non-fibrous (Other)

60%

25%

Cellulose

Glass

5%

10%

Black

Non-Fibrous

Homogeneous

Comp. Roof Silver w

black tar and felt

paper - Roof B (Trellis

Roof) Roof NE Corner

Field

170713-2-Roofing

091714698-0002

None DetectedMatrix

Non-fibrous (Other)

60%

30%

Glass10%Black

Non-Fibrous

Homogeneous

Comp. Roof Silver w

black tar and felt


Roof) Roof NW

Corner Field

170713-2-Insulation

091714698-0002A

None DetectedNon-fibrous (Other)5%Cellulose

Min. Wool

20%

75%

Gray/Yellow

Fibrous

Homogeneous

Comp. Roof Silver w

black tar and felt


Roof) Roof NW

Corner Field

170713-3-Roofing

091714698-0003

None DetectedQuartz

Matrix

Non-fibrous (Other)

10%

60%

15%

Glass15%Red/Black

Non-Fibrous

Homogeneous

Comp Roof (A) w Red

rock/black tar - Bldg D

Roof A SW Core Field

170713-3-Tar

091714698-0003A

None DetectedMatrix

Non-fibrous (Other)

70%

30%

Black

Non-Fibrous

Homogeneous

Comp Roof (A) w Red



170713-3-Insulation

091714698-0003B

None DetectedCellulose

Min. Wool

25%

75%

Gray/Yellow

Fibrous

Homogeneous

Comp Roof (A) w Red



170713-4-Roofing

091714698-0004

None DetectedQuartz

Matrix

Non-fibrous (Other)

12%

60%

13%

Glass15%Red/Black

Non-Fibrous

Homogeneous

Comp Roof (A) w Red


Roof A NE Core Field

170713-4-Tar

091714698-0004A

None DetectedMatrix

Non-fibrous (Other)

70%

30%

Black

Non-Fibrous

Homogeneous

Comp Roof (A) w Red



170713-4-Insulation

091714698-0004B

None DetectedCellulose

Min. Wool

15%

85%

Gray/Yellow

Fibrous

Homogeneous

Comp Roof (A) w Red



170713-5

091714698-0005

None DetectedMatrix15%Cellulose85%Black

Fibrous

Homogeneous

Roof Tile Vapor

Barrier Black - Bldg D

Roof Tile SW Center

170713-6

091714698-0006

None DetectedMatrix20%Cellulose80%Black

Fibrous

Homogeneous

Roof Tile Vapor

Barrier Black - Bldg D

Roof Tile SE Center

170713-7

091714698-0007

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

30%

50%

20%

Gray/White

Non-Fibrous

Homogeneous

Flashing Mastic White

- Trellis Roof S Edge

170713-8

091714698-0008

None DetectedMatrix

Non-fibrous (Other)

60%

25%

Cellulose15%Black

Non-Fibrous

Homogeneous

Penetration Mastic

Black - Trellis Roof

NE Corner

170713-9

091714698-0009

None DetectedMatrix

Non-fibrous (Other)

60%

25%

Cellulose15%Black

Non-Fibrous

Homogeneous

Penetration Mastic

Black - Trellis Roof

NW Corner

Initial report from: 07/24/2017 09:40:33

Page 1 of 7ASB_PLM_0008_0001 - 1.78 Printed: 7/24/2017 9:40 AM


Tel/Fax: (510) 895-3675 / (510) 895-3680



Customer ID: MLAN42

Customer PO: 1048

Project ID:


Light Microscopy



% Type

170713-10

091714698-0010

None DetectedMatrix

Non-fibrous (Other)

65%

35%

Gray

Non-Fibrous

Homogeneous

Flashing Mastic Grey

- Bldg D Roof NW

Corner

170713-11

091714698-0011

None DetectedMatrix

Non-fibrous (Other)

70%

30%

Gray

Non-Fibrous

Homogeneous

Flashing Mastic Grey

- Bldg D Roof NE

Corner

170713-12

091714698-0012

None DetectedMatrix

Non-fibrous (Other)

70%

30%

Gray

Non-Fibrous

Homogeneous

Mastic Dark Grey

Flashing Cap on Post

- Bldg D Roof


NE Cor

170713-13

091714698-0013

None DetectedMatrix

Non-fibrous (Other)

70%

30%

Gray

Non-Fibrous

Homogeneous

Mastic Dark Grey


- Bldg D Roof


NW Cor

170713-14

091714698-0014

None DetectedMatrix

Non-fibrous (Other)

65%

35%

Gray

Non-Fibrous

Homogeneous

Mastic Dark Grey

Water Spigot Skeve -

Bldg D Roof N Center

Under The Roof

170713-15-Mortar

091714698-0015

None DetectedQuartz

Non-fibrous (Other)

35%

65%

Gray

Non-Fibrous

Homogeneous

Martar Bed Grey

Under Brown Tile -

Bldg D Mens RR H/C

Stahl NE Cor

170713-15-Tile

091714698-0015A

None DetectedQuartz

Non-fibrous (Other)

35%

65%

Brown

Non-Fibrous

Homogeneous

Martar Bed Grey

Under Brown Tile -

Bldg D Mens RR H/C

Stahl NE Cor

170713-15-Grout

091714698-0015B

None DetectedQuartz

Non-fibrous (Other)

40%

60%

Brown/Purple

Non-Fibrous

Homogeneous

Martar Bed Grey

Under Brown Tile -

Bldg D Mens RR H/C

Stahl NE Cor

170713-16-Mortar

091714698-0016

None DetectedQuartz

Non-fibrous (Other)

45%

55%

Gray

Non-Fibrous

Homogeneous

Martar Bed Grey

Under Green Tile -

Bldg D Mens RR H/C

Stahl NE Cor

170713-16-Tile

091714698-0016A

None DetectedQuartz

Non-fibrous (Other)

35%

65%

Gray/Green

Non-Fibrous

Homogeneous

Martar Bed Grey

Under Green Tile -

Bldg D Mens RR H/C

Stahl NE Cor

170713-17

091714698-0017

None DetectedQuartz

Non-fibrous (Other)

40%

60%

Brown/Red

Non-Fibrous

Homogeneous

Grout Brown from

Brown Tile - Bldg D

Mens RR H/C Stahl

NE Cor

170713-18

091714698-0018

None DetectedQuartz

Non-fibrous (Other)

35%

65%

Brown

Non-Fibrous

Homogeneous

Grout Grey from

Green Tile - Bldg D

Mens RR H/C Stahl

NE Cor

170713-19

091714698-0019

None DetectedQuartz

Non-fibrous (Other)

40%

60%

Gray

Non-Fibrous

Homogeneous

Grout Grey from

Green Tile - Bldg D

Womens RR H/C

Stahl NW Cor

170713-20

091714698-0020

None DetectedQuartz

Non-fibrous (Other)

40%

60%

Brown

Non-Fibrous

Homogeneous

Grout Brown Off

Brown Tile - Bldg D

Womens RR NW

Corner




Tel/Fax: (510) 895-3675 / (510) 895-3680



Customer ID: MLAN42

Customer PO: 1048

Project ID:


Light Microscopy



% Type

170713-21-Mortar

091714698-0021

None DetectedQuartz

Non-fibrous (Other)

40%

60%

Gray

Non-Fibrous

Homogeneous

Mortar Bed Lt Grey

Under Green Tile -

Bldg D Women RR

NW Corner

170713-21-Tile

091714698-0021A

None DetectedQuartz

Non-fibrous (Other)

35%

65%

Brown/Green

Non-Fibrous

Homogeneous

Mortar Bed Lt Grey

Under Green Tile -

Bldg D Women RR

NW Corner

170713-22-Mortar

091714698-0022

None DetectedQuartz

Non-fibrous (Other)

45%

55%

Gray

Non-Fibrous

Homogeneous

Mortar Bed Lt Grey

Under Brown Tile -

Bldg D Women RR

NW Corner

170713-22-Tile

091714698-0022A

None DetectedQuartz

Non-fibrous (Other)

30%

70%

Brown

Non-Fibrous

Homogeneous

Mortar Bed Lt Grey

Under Brown Tile -

Bldg D Women RR

NW Corner

170713-23-Carpet

091714698-0023

None DetectedNon-fibrous (Other)10%Synthetic90%Gray

Fibrous

Homogeneous

Grey Carpet W/Yellow

Mastic - Bldg D Nebs

RR/NE Cor @ Dor

170713-23-Mastic

091714698-0023A

None DetectedMatrix

Non-fibrous (Other)

70%

30%

Yellow

Non-Fibrous

Homogeneous

Grey Carpet W/Yellow

Mastic - Bldg D Nebs

RR/NE Cor @ Dor

170713-24-Cove Base

091714698-0024


Matrix

Non-fibrous (Other)

50%

40%

10%

Black

Non-Fibrous

Homogeneous

Covebase Black 6"

w/White yellow mastic

- Bldg D Waiting

Room of Faculty RR

Center N Wall

170713-24-Mastic

091714698-0024A


Non-fibrous (Other)

50%

50%

White/Yellow

Non-Fibrous

Homogeneous

Covebase Black 6"

w/White yellow mastic

- Bldg D Waiting

Room of Faculty RR

Center N Wall

170713-25-Carpet

091714698-0025

None DetectedNon-fibrous (Other)5%Synthetic95%Brown/Black

Fibrous

Homogeneous

Carpet Brown w/black

spots and yellow

mastic - Bldg D Office

#4 NE Cor

170713-25-Mastic

091714698-0025A

None DetectedMatrix

Non-fibrous (Other)

70%

30%

Yellow

Non-Fibrous

Homogeneous


spots and yellow


#4 NE Cor

170713-26-Cove Base

091714698-0026


Matrix

Non-fibrous (Other)

50%

35%

15%

Tan

Non-Fibrous

Homogeneous

Covebase Tan

w/white mastic - Bldg

D Office #1 NE Cor

170713-26-Mastic

091714698-0026A

None DetectedMatrix

Non-fibrous (Other)

50%

50%

Tan

Non-Fibrous

Homogeneous

Covebase Tan


D Office #1 NE Cor

170713-26-Compound

091714698-0026B


Non-fibrous (Other)

70%

30%

White

Non-Fibrous

Homogeneous

Covebase Tan


D Office #1 NE Cor

170713-27-Drywall

091714698-0027

None DetectedGypsum

Non-fibrous (Other)

70%

28%

Cellulose2%White

Fibrous

Homogeneous

DWS Tan Corner -

Bldg D Office #1 NE

Corner

170713-27-Joint

Compound

091714698-0027A


Non-fibrous (Other)

80%

20%

White

Non-Fibrous

Homogeneous

DWS Tan Corner -

Bldg D Office #1 NE

Corner

170713-28-Drywall

091714698-0028

None DetectedGypsum

Non-fibrous (Other)

70%

28%

Cellulose

Glass

2%

<1%

White

Fibrous

Homogeneous

DWS Tan Field - Bldg

D Office N Wall




Tel/Fax: (510) 895-3675 / (510) 895-3680



Customer ID: MLAN42

Customer PO: 1048

Project ID:


Light Microscopy



% Type

170713-28-Joint

Compound

091714698-0028A

Not SubmittedDWS Tan Field - Bldg

D Office N Wall

No Joint Compound present in sample

170713-29-Cove Base

091714698-0029


Matrix

Non-fibrous (Other)

50%

35%

15%

Tan

Non-Fibrous

Homogeneous

Covebase Tan


D Office #6 NE

Corner

170713-29-Mastic

091714698-0029A

None DetectedMatrix

Non-fibrous (Other)

50%

50%

Tan

Non-Fibrous

Homogeneous

Covebase Tan


D Office #6 NE

Corner

170713-29-Compound

091714698-0029B


Non-fibrous (Other)

70%

30%

White

Non-Fibrous

Homogeneous

Covebase Tan


D Office #6 NE

Corner

170713-30-Carpet

091714698-0030

None DetectedNon-fibrous (Other)5%Synthetic95%Brown/Black

Fibrous

Homogeneous


spots with yellow


#1 NW Corner

170713-30-Mastic

091714698-0030A

None DetectedMatrix

Non-fibrous (Other)

60%

40%

Yellow

Non-Fibrous

Homogeneous


spots with yellow


#1 NW Corner

170713-31

091714698-0031

None DetectedPerlite

Non-fibrous (Other)

10%

30%

Cellulose

Min. Wool

40%

20%

Tan

Fibrous

Homogeneous

LCT White w/random

hooks and channels -

Bldg D Office #1

Ceiling W Center

170713-32

091714698-0032

None DetectedPerlite

Non-fibrous (Other)

10%

30%

Cellulose

Min. Wool

40%

20%

Tan

Fibrous

Homogeneous

LCT White w/random

hooks and channels -

A+D Bldg Office #4

Ceiling SW Corner

170713-33

091714698-0033

None DetectedQuartz

Ca Carbonate

Non-fibrous (Other)

30%

50%

20%

Gray

Non-Fibrous

Homogeneous

Column Texture White

Pebble Texture - Bldg

D Office #4 NE

Corner

170713-34

091714698-0034

None DetectedQuartz

Ca Carbonate

Non-fibrous (Other)

30%

50%

20%

Gray

Non-Fibrous

Homogeneous


Pebble Texture - Bldg

D Office #15 SE

Corner

170713-35-RFT

091714698-0035

<1% ChrysotileCa Carbonate

Non-fibrous (Other)

50%

50%

Gray

Non-Fibrous

Homogeneous

RFT Grey Brown

Striatius Black Mastic

- Bldg D Janitors

Closet SE Corner

170713-35-Mastic

091714698-0035A

5% ChrysotileMatrix

Non-fibrous (Other)

50%

45%

Black

Non-Fibrous

Homogeneous

RFT Grey Brown


- Bldg D Janitors

Closet SE Corner

170713-36-RFT

091714698-0036


Non-fibrous (Other)

50%

50%

Gray

Non-Fibrous

Homogeneous

RFT Grey Brown


- Bldg D Janitors

Closet SW Corner

170713-36-Mastic

091714698-0036A

Positive Stop (Not Analyzed)RFT Grey Brown


- Bldg D Janitors

Closet SW Corner




Tel/Fax: (510) 895-3675 / (510) 895-3680



Customer ID: MLAN42

Customer PO: 1048

Project ID:


Light Microscopy



% Type

170713-37-RFT

091714698-0037


Non-fibrous (Other)

45%

55%

Brown/Gray

Non-Fibrous

Homogeneous

RFT Gray Brown with

White+Brown

stratious/yellow

mastic - Bldg D North

Storage SW Corner

170713-37-Mastic

091714698-0037A

None DetectedMatrix

Non-fibrous (Other)

65%

35%

Yellow

Non-Fibrous

Homogeneous

RFT Gray Brown with

White+Brown

stratious/yellow

mastic - Bldg D North

Storage SW Corner

170713-38

091714698-0038

3% ChrysotileMatrix

Non-fibrous (Other)

60%

37%

Black

Non-Fibrous

Homogeneous

Sink Sounds Proofing

Black - Bldg D

Workroom S Wall

Center

170713-39-Carpet

091714698-0039

None DetectedNon-fibrous (Other)5%Synthetic95%Gray/Blue

Fibrous

Homogeneous

Carpet Tile blue grey

yellow mastic - Vldg D

S Floor Work Room

@ Door

170713-39-Mastic

091714698-0039A

None DetectedMatrix

Non-fibrous (Other)

60%

40%

Yellow

Non-Fibrous

Homogeneous

Carpet Tile blue grey

yellow mastic - Vldg D

S Floor Work Room

@ Door

170713-40-Drywall

091714698-0040

None DetectedGypsum

Non-fibrous (Other)

80%

17%

Cellulose3%White

Non-Fibrous

Homogeneous

DWS Yellow White -

Bldg D Work Room E

Wall S Corner

170713-40-Joint

Compound

091714698-0040A


Non-fibrous (Other)

80%

20%

White

Non-Fibrous

Homogeneous

DWS Yellow White -

Bldg D Work Room E

Wall S Corner

170713-41-Cove Base

091714698-0041


Matrix

Non-fibrous (Other)

50%

30%

20%

Black

Non-Fibrous

Homogeneous

Covebase Black 6"

w/yellow mastic - Bldg

D Work Room E Wall

S Corner

170713-41-Mastic

091714698-0041A


Matrix

Non-fibrous (Other)

20%

60%

20%

Beige

Non-Fibrous

Homogeneous

Covebase Black 6"


D Work Room E Wall

S Corner

170713-41-Compound

091714698-0041B


Non-fibrous (Other)

70%

30%

White

Non-Fibrous

Homogeneous

Covebase Black 6"


D Work Room E Wall

S Corner

170713-42-Carpet

091714698-0042

None DetectedNon-fibrous (Other)10%Synthetic90%Gray

Fibrous

Homogeneous

Carpet Blue Grey

W/yellow mastic -

Bldg D Admin

Reception NE Corner

170713-42-Mastic

091714698-0042A

None DetectedMatrix

Non-fibrous (Other)

80%

20%

Tan

Non-Fibrous

Homogeneous

Carpet Blue Grey

W/yellow mastic -

Bldg D Admin

Reception NE Corner

170713-43-Drywall

091714698-0043

None DetectedGypsum

Non-fibrous (Other)

80%

18%

Cellulose

Glass

2%

<1%

White

Non-Fibrous

Homogeneous

DWS White - Bldg D

Admin Receoption NE

Corner

170713-43-Joint

Compound

091714698-0043A

2% ChrysotileCa Carbonate

Non-fibrous (Other)

80%

18%

White

Non-Fibrous

Homogeneous

DWS White - Bldg D

Admin Receoption NE

Corner




Tel/Fax: (510) 895-3675 / (510) 895-3680



Customer ID: MLAN42

Customer PO: 1048

Project ID:


Light Microscopy



% Type

170713-44-Cove Base

091714698-0044


Matrix

Non-fibrous (Other)

50%

30%

20%

Brown

Non-Fibrous

Homogeneous

Covebase Grey

Brown w/yellow

mastic - Bldg D Rm

16 NE Corner

170713-44-Mastic

091714698-0044A


Matrix

Non-fibrous (Other)

20%

60%

20%

Beige

Non-Fibrous

Homogeneous

Covebase Grey

Brown w/yellow

mastic - Bldg D Rm

16 NE Corner

170713-44-Compound

091714698-0044B

2% ChrysotileCa Carbonate

Non-fibrous (Other)

70%

28%

White

Non-Fibrous

Homogeneous

Covebase Grey

Brown w/yellow

mastic - Bldg D Rm

16 NE Corner

170713-45-Carpet

091714698-0045

None DetectedNon-fibrous (Other)20%Synthetic80%Gray/Blue

Fibrous

Homogeneous

Carpet Blue yellow

white pebble pattern -

Bldg D Rn 16 NE

Corner

170713-45-Mastic

091714698-0045A

None DetectedMatrix

Non-fibrous (Other)

80%

20%

Brown

Non-Fibrous

Homogeneous

Carpet Blue yellow

white pebble pattern -

Bldg D Rn 16 NE

Corner

170713-46

091714698-0046

None DetectedQuartz

Ca Carbonate

Non-fibrous (Other)

20%

60%

20%

White

Non-Fibrous

Homogeneous


- Bldg D Rm 16 NE

Corner

170713-47-Cove Base

091714698-0047


Matrix

Non-fibrous (Other)

50%

30%

20%

Black

Non-Fibrous

Homogeneous

Covebase black 6"

yellow mastic - Bldg D

E Hallway SW Corner

170713-47-Mastic

091714698-0047A


Matrix

Non-fibrous (Other)

20%

60%

20%

Tan

Non-Fibrous

Homogeneous

Covebase black 6"


E Hallway SW Corner

170713-47-Compound

091714698-0047B


Non-fibrous (Other)

70%

30%

White

Non-Fibrous

Homogeneous

Covebase black 6"


E Hallway SW Corner

170713-48-Floor Tile

091714698-0048


Non-fibrous (Other)

70%

30%

White

Non-Fibrous

Homogeneous

RFT Lt+Grey w dark

gray lineations/yellow

brown mastic - Bldg D

E Hallway W Wall

Center

170713-48-Mastic

091714698-0048A

None DetectedMatrix

Non-fibrous (Other)

80%

20%

Tan

Non-Fibrous

Homogeneous

RFT Lt+Grey w dark



E Hallway W Wall

Center

170713-49-Floor Tile

091714698-0049


Non-fibrous (Other)

70%

30%

White

Non-Fibrous

Homogeneous

RFT Lt+Grey w dark



E Hallway S Wall

Center

170713-49-Mastic

091714698-0049A

None DetectedMatrix

Non-fibrous (Other)

80%

20%

Brown

Non-Fibrous

Homogeneous

RFT Lt+Grey w dark



E Hallway S Wall

Center

170713-50-Cove Base

091714698-0050


Matrix

Non-fibrous (Other)

50%

30%

20%

Black

Non-Fibrous

Homogeneous

Covebase Black 4"

Yellow Masitc - Bldg

D E Hallway N Wall

Center Locker




Tel/Fax: (510) 895-3675 / (510) 895-3680



Customer ID: MLAN42

Customer PO: 1048

Project ID:


Light Microscopy



% Type

170713-50-Mastic

091714698-0050A

None DetectedMatrix

Non-fibrous (Other)

80%

20%

Tan

Non-Fibrous

Homogeneous

Covebase Black 4"

Yellow Masitc - Bldg

D E Hallway N Wall

Center Locker

170713-51

091714698-0051

None DetectedQuartz

Ca Carbonate

Non-fibrous (Other)

20%

60%

20%

Gray

Non-Fibrous

Homogeneous

Ext Column Stucco

White - Bldg D SW

Corner Column

170713-52

091714698-0052


Matrix

Non-fibrous (Other)

10%

70%

20%

Gray

Non-Fibrous

Homogeneous

Sealant Gray - Bldg D

Sidewalk Exp Joint

SW Corner

170713-53

091714698-0053


Matrix

Non-fibrous (Other)

5%

80%

15%

Beige

Non-Fibrous

Homogeneous

Door Caulking Grey -

Bldg D Exterior W

Hallway Door/W Side

Low

170713-54

091714698-0054

None DetectedQuartz

Ca Carbonate

Non-fibrous (Other)

20%

60%

20%

Gray

Non-Fibrous

Homogeneous

Stucco White Upper

Exterior - Bldg D

Exterior Wall EASt N

Center @ Column 3

170713-55

091714698-0055

None DetectedQuartz

Ca Carbonate

Non-fibrous (Other)

20%

60%

20%

Tan

Non-Fibrous

Homogeneous

Spray Coating White

on Concrete Lower -

Bldg D Exterior Wall

EASt N Center @

Column 3

Analyst(s)

Beheshta Ahadi (57)

Shane Heisser (33)

Matthew Batongbacal

or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . This report relates only to the samples reported and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no

responsibility for sample collection activities or analytical method limitations. Interpretation and use of test results are the responsibility of the client. This report must not be used by the client to claim

product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government . Non-friable organically bound materials present a problem matrix and therefore EMSL

recommends gravimetric reduction prior to analysis. Samples received in good condition unless otherwise noted. Estimated accuracy, precision and uncertainty data available upon request. Unless

requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Reporting limit is 1%

Samples analyzed by EMSL Analytical, Inc San Leandro, CA NVLAP Lab Code 101048-3, WA C884




Phone/Fax: (510) 895-3675 / (510) 895-3680


EMSL Order: 091714698

Customer ID: MLAN42

Customer PO: 1048

Project ID:

Attention: Mark Milani Phone: (925) 330-7642

Milani & Associates Fax:

2655 Stanwell Drive Received: 07/17/2017 11:45 AM

Suite 105 Analysis Date: 07/23/2017 - 07/24/2017

Concord, CA 94520 Collected:

Project:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using

Polarized Light Microscopy. Quantitation using 400 Point Count Procedure

Sample Description Appearance % Fibrous % Non-Fibrous % Type


White

Non-Fibrous

Homogeneous

DWS Yellow White -

Bldg D Work Room E

Wall S Corner

170713-40-Joint

Compound

091714698-0040A

Non-fibrous (Other)99.75% 0.25%Chrysotile

White

Non-Fibrous

Homogeneous

Covebase Black 6"


D Work Room E Wall S

Corner

170713-41-Compou

nd

091714698-0041B


White

Non-Fibrous

Homogeneous

Covebase black 6"


E Hallway SW Corner

170713-47-Compou

nd

091714698-0047B


Analyst(s)

Shane Heisser (3) Matthew Batongbacal

or other approved signatory

Disclaimer:Some samples may contain asbestos fibers present in dimensions below PLM resolution limits. The limit of detection as stated in the method is 0.25%. EMSL Analytical Inc suggests

that samples reported as <0.25% or none detected undergo additional analysis via TEM . The above test report relates only to the items tested. This report may not be reproduced, except in full,

without written approval of EMSL Analytical Inc. This test report must not be used by the client to claim product endorsement by NVLAP or any agency of the United States Government . EMSL

Analytical Inc., bears no responsibility for sample collection activities, analytical method limitations, or the accuracy of results when requested to separate layered samples. EMSL Analytical

Inc., liability is limited to the cost of sample analysis.The test results contained within this report meet the requirements of NELAC unless otherwise noted. Samples received in good condition

unless otherwise noted. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample.



ASB_PLMPC_0006_0003 Printed 7/24/2017 9:40:49AM Page 1 of 1


Phone/Fax: (510) 895-3675 / (510) 895-3680


EMSL Order: 091714698

Customer ID: MLAN42

Customer PO: 1048

Project ID:

Attention: Mark Milani Phone: (925) 330-7642

Milani & Associates Fax:

2655 Stanwell Drive Received: 07/17/2017 11:45 AM

Suite 105 Analysis Date: 07/23/2017 - 07/26/2017

Concord, CA 94520 Collected:

Project: 1048 - PHS Admin Bldg Demo

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using

Polarized Light Microscopy. Quantitation using 400 Point Count Procedure

Sample Description Appearance % Fibrous % Non-Fibrous % Type


White

Non-Fibrous

Homogeneous

DWS Yellow White -

Bldg D Work Room E

Wall S Corner

170713-40-Joint

Compound

091714698-0040A


White

Non-Fibrous

Homogeneous

Covebase Black 6"


D Work Room E Wall S

Corner

170713-41-Compou

nd

091714698-0041B


White

Non-Fibrous

Homogeneous

DWS White - Bldg D

Admin Receoption NE

Corner

170713-43-Joint

Compound

091714698-0043A

Non-fibrous (Other)100% <0.25%Chrysotile

White

Non-Fibrous

Homogeneous

Covebase Grey Brown


D Rm 16 NE Corner

170713-44-Compou

nd

091714698-0044B

Non-fibrous (Other)100% <0.25%Chrysotile

White

Non-Fibrous

Homogeneous

Covebase black 6"


E Hallway SW Corner

170713-47-Compou

nd

091714698-0047B


Analyst(s)

Adam C. Fink (2)

Shane Heisser (3)

Matthew Batongbacal

or other approved signatory

Disclaimer:Some samples may contain asbestos fibers present in dimensions below PLM resolution limits. The limit of detection as stated in the method is 0.25%. EMSL Analytical Inc suggests

that samples reported as <0.25% or none detected undergo additional analysis via TEM . The above test report relates only to the items tested. This report may not be reproduced, except in full,

without written approval of EMSL Analytical Inc. This test report must not be used by the client to claim product endorsement by NVLAP or any agency of the United States Government . EMSL

Analytical Inc., bears no responsibility for sample collection activities, analytical method limitations, or the accuracy of results when requested to separate layered samples. EMSL Analytical

Inc., liability is limited to the cost of sample analysis.The test results contained within this report meet the requirements of NELAC unless otherwise noted. Samples received in good condition

unless otherwise noted. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample.


Report amended: 07/24/2017 11:24:23 Replaces initial report from: 07/24/2017 09:40:51 Reason Code: Client-Change to Project

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Tel/Fax: (510) 895-3675 / (510) 895-3680



Customer ID: MLAN42

Customer PO: 1048-2018-1

Project ID:

Attention: Phone:Mark Milani (925) 330-7642

Fax:Milani & Associates

Received Date:2655 Stanwell Drive 05/16/2018 12:00 PM

Analysis Date:Suite 105 05/16/2018

Collected Date:Concord, CA 94520 05/10/2018

Project: 1048 / PHS Bldg D


Light Microscopy



% Type

180510-101

091810382-0001

None DetectedQuartz

Ca Carbonate

Non-fibrous (Other)

20%

50%

30%

Gray

Non-Fibrous

Homogeneous

Concrete, Gray - SW

Exterior Door

Analyst(s)

Beheshta Ahadi (1) Matthew Batongbacal

or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . This report relates only to the samples reported and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no

responsibility for sample collection activities or analytical method limitations. Interpretation and use of test results are the responsibility of the client. This report must not be used by the client to claim

product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government . Non-friable organically bound materials present a problem matrix and therefore EMSL

recommends gravimetric reduction prior to analysis. Samples received in good condition unless otherwise noted. Estimated accuracy, precision and uncertainty data available upon request. Unless

requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Reporting limit is 1%



Page 1 of 1ASB_PLM_0008_0001 - 1.78 Printed: 5/16/2018 5:33 PM

OrderID: 091810382

Page 1 Of 2

OrderID: 091810382

Page 2 Of 2

WorkOrder:

Report Created for: Milani & Associates

2520 Stanwell Drive Ste 250

Concord, CA 94520

Project Contact: Mark Milani

Project Name: 1048; Admin (Bldg D) Building Demo Survey

Project P.O.: 1048

Project Received: 07/17/2017

Analytical Report reviewed & approved for release on 07/21/2017 by:

Angela Rydelius,

Laboratory Manager

1707530

The report shall not be reproduced except in full, without the written

approval of the laboratory. The analytical results relate only to the

items tested. Results reported conform to the most current NELAP

standards, where applicable, unless otherwise stated in the case

narrative.

Analytical Report

1534 Willow Pass Rd. Pittsburg, CA 94565 ♦ TEL: (877) 252-9262 ♦ FAX: (925) 252-9269 ♦ www.mccampbell.com

CA ELAP 1644 ♦ NELAP 4033ORELAP

McCampbell Analytical, Inc."When Quality Counts"

Page 1 of 8

Glossary of Terms & Qualifier Definitions

Client: Milani & Associates

Project: 1048; Admin (Bldg D) Building Demo Survey

WorkOrder: 1707530

McCampbell Analytical, Inc.1534 Willow Pass Road, Pittsburg, CA 94565-1701

Toll Free Telephone: (877) 252-9262 / Fax: (925) 252-9269

http://www.mccampbell.com / E-mail: [email protected]"When Quality Counts"

Glossary Abbreviation

%D Serial Dilution Percent Difference

95% Interval 95% Confident Interval

DF Dilution Factor

DI WET (DISTLC) Waste Extraction Test using DI water

DISS Dissolved (direct analysis of 0.45 µm filtered and acidified water sample)

DLT Dilution Test (Serial Dilution)

DUP Duplicate

EDL Estimated Detection Limit

ERS External reference sample. Second source calibration verification.

ITEF International Toxicity Equivalence Factor

LCS Laboratory Control Sample

MB Method Blank

MB % Rec % Recovery of Surrogate in Method Blank, if applicable

MDL Method Detection Limit

ML Minimum Level of Quantitation

MS Matrix Spike

MSD Matrix Spike Duplicate

N/A Not Applicable

ND Not detected at or above the indicated MDL or RL

NR Data Not Reported due to matrix interference or insufficient sample amount.

PDS Post Digestion Spike

PDSD Post Digestion Spike Duplicate

PF Prep Factor

RD Relative Difference

RL Reporting Limit (The RL is the lowest calibration standard in a multipoint calibration.)

RPD Relative Percent Deviation

RRT Relative Retention Time

SPK Val Spike Value

SPKRef Val Spike Reference Value

SPLP Synthetic Precipitation Leachate Procedure

ST Sorbent Tube

TCLP Toxicity Characteristic Leachate Procedure

TEQ Toxicity Equivalents

WET (STLC) Waste Extraction Test (Soluble Threshold Limit Concentration)

Page 2 of 8

Analytical Report






Date Received: 7/17/17 12:30

Date Prepared: 7/17/17

WorkOrder: 1707530

Extraction Method: SW3050B

Analytical Method: SW6020

Unit: mg/Kg

Lead

170713-101L/Ceramic Floor Tile, Brown, Mens 1707530-001A Solid 07/13/2017 ICP-MS3 142086

Analytes Result DF Date AnalyzedRL

Client ID Lab ID Matrix Date Collected Instrument Batch ID

Lead 7.3 0.50 1 07/17/2017 23:57

Surrogates REC (%) Limits

Analyst(s): ND

Terbium 106 70-130 07/17/2017 23:57

170713-102L/ Ceramic Floor Tile, Brown, Women 1707530-002A Solid 07/13/2017 ICP-MS3 142086



Lead 0.55 0.50 1 07/18/2017 00:03


Analyst(s): ND

Terbium 104 70-130 07/18/2017 00:03

170713-103L/ Ceramic Wall Tile, Green Mens RR 1707530-003A Solid 07/13/2017 ICP-MS3 142086



Lead 0.58 0.50 1 07/18/2017 00:09


Analyst(s): ND

Terbium 110 70-130 07/18/2017 00:09

170713-104L/Ceramic Wall Tile, Green Womens 1707530-004A Solid 07/13/2017 ICP-MS3 142086



Lead ND 0.50 1 07/18/2017 00:15


Analyst(s): ND

Terbium 100 70-130 07/18/2017 00:15

Angela Rydelius, Lab ManagerCDPH ELAP 1644 • NELAP 4033ORELAP

Page 3 of 8

Quality Control Report






Date Analyzed: 7/18/17

Date Prepared: 7/17/17

WorkOrder: 1707530

BatchID: 142086

Analytical Method: SW6020

Unit: mg/Kg

Sample ID: MB/LCS-142086

1707520-001AMS/MSD

Instrument: ICP-MS2

Matrix: Soil

Extraction Method: SW3050B

QC Summary Report for Metals

Analyte MB

Result

LCS

Result

RL SPK

Val

MB SS

%REC

LCS

%REC

LCS

Limits

Lead ND 50.6 0.50 50 - 101 75-125

Surrogate Recovery

Terbium 532.7 496 500 107 99 70-130

Analyte MS

Result

MSD

Result

SPK

Val

SPKRef

Val

MS

%REC

MSD

%REC

MS/MSD

Limits

RPD RPD

Limit

Lead 50.0 53.6 50 2.783 94 102 75-125 6.99 20

Surrogate Recovery

Terbium 472 504 500 94 101 70-130 6.58 20

Analyte DLT

Result

DLTRef

Val

%D %D

Limit

Lead 2.94 2.783 5.64 -

%D Control Limit applied to analytes with concentrations greater than 25 times the reporting limits.

QA/QC OfficerCDPH ELAP 1644 • NELAP 4033ORELAP

Page 4 of 8

McCampbell Analytical, Inc.1534 Willow Pass Rd

Pittsburg, CA 94565-1701

(925) 252-9262

CHAIN-OF-CUSTODY RECORD Page

Lab ID Matrix Collection Date Hold

Requested Tests (See legend below)

Report to:

Mark Milani


Concord, CA 94520

(925) 674-9082 FAX:

PO: 1048

07/17/2017

Client ID

ProjectNo: 1048; Admin (Bldg D) Building Demo Survey

WorkOrder: 1707530

1 of 1

Date Logged:

Date Received: 07/17/2017

1 2 3 4 5 6 7 8 9 10 11 12

Milani & Associates

Bill to:

Mark Milani

Milani & Associates


Concord, CA 94520

Requested TAT: 5 days;

ClientCode: MACC

Email: [email protected]

EDF EQuIS Email HardCopy ThirdParty

[email protected]

Excel J-flagWriteOn

cc/3rd Party:

WaterTrax

A1707530-001 Solid 7/13/2017 00:00170713-101L/Ceramic Floor Tile, Brown,

A1707530-002 Solid 7/13/2017 00:00170713-102L/ Ceramic Floor Tile, Brown,

A1707530-003 Solid 7/13/2017 00:00170713-103L/ Ceramic Wall Tile, Green

A1707530-004 Solid 7/13/2017 00:00170713-104L/Ceramic Wall Tile, Green

Prepared by: Jena Alfaro

NOTE: Soil samples are discarded 60 days after results are reported unless other arrangements are made (Water samples are 30 days). Hazardous samples will be returned to client or disposed of at client expense.

Comments:

PBMS_TTLC_S1 2 3 4

5 6 7 8

9 10

Test Legend:

11 12

Page 5 of 8

Lab ID Client ID Collection Date

& Time

Date Logged:

TATMatrix Test Name Containers

/Composites

WORK ORDER SUMMARY

Work Order: 1707530

Comments:

Client Name: MILANI & ASSOCIATES Project: 1048; Admin (Bldg D) Building Demo Survey

QC Level: LEVEL 2

HoldDe-

chlorinated

SubOutBottle & Preservative

7/17/2017

Sediment

Content

EDF Fax Email HardCopy ThirdPartyExcel J-flagWriteOn

Mark MilaniClient Contact:

[email protected]'s Email:

WaterTrax




1707530-001A 170713-101L/Ceramic Floor

Tile, Brown, Mens

7/13/2017 5 daysSolid SW6020 (Lead) 1 Plastic Baggie, Small

1707530-002A 170713-102L/ Ceramic Floor

Tile, Brown, Womens RR


1707530-003A 170713-103L/ Ceramic Wall

Tile, Green Mens RR


1707530-004A 170713-104L/Ceramic Wall

Tile, Green Womens RR


1 of 1Page

- STLC and TCLP extractions require 2 days to complete; therefore, all TATs begin after the extraction is completed (i.e., One-day TAT yields results

in 3 days from sample submission).

NOTES:

- MAI assumes that all material present in the provided sampling container is considered part of the sample - MAI does not exclude any material from

the sample prior to sample preparation unless requested in writing by the client.

Page 6 of 8

Page 7 of 8

Sample Receipt Checklist




Client Name: Milani & Associates

WorkOrder №: 1707530

Date Logged: 7/17/2017

Logged by: Jena AlfaroMatrix: Solid

Carrier: Client Drop-In

Shipping container/cooler in good condition? Yes No

Custody seals intact on shipping container/cooler? Yes No NA

Samples Received on Ice? Yes No

Chain of custody present? Yes No

Chain of custody signed when relinquished and received? Yes No

Chain of custody agrees with sample labels? Yes No

Samples in proper containers/bottles? Yes No

Sample containers intact? Yes No

Sufficient sample volume for indicated test? Yes No

NAAll samples received within holding time? Yes No

NASample/Temp Blank temperature

Yes No NAWater - VOA vials have zero headspace / no bubbles?

pH acceptable upon receipt (Metal: <2; 522: <4; 218.7: >8)? Yes No NA

Temp:

Chain of Custody (COC) Information

Yes NoSample IDs noted by Client on COC?

Yes NoDate and Time of collection noted by Client on COC?

Yes NoSampler's name noted on COC?

Sample Receipt Information

Sample Preservation and Hold Time (HT) Information

Sample labels checked for correct preservation? Yes No

Project Name: 1048; Admin (Bldg D) Building Demo Survey

Comments:

Total Chlorine tested and acceptable upon receipt for EPA 522? Yes No NA

UCMR Samples:

Free Chlorine tested and acceptable upon receipt for EPA 218.7, 300.1, 537, 539?

Yes No NA

Date and Time Received 7/17/2017 12:30

Received by: Jena Alfaro

Page 8 of 8

United States Department of Commerce National Institute of Standards and Technology

Certificate of Accreditation to ISO/IEC 17025:2005

NVLAP LAB CODE: 101048-3

EMSL Analytical, Inc.San Leandro, CA

is accredited by the National Voluntary Laboratory Accreditation Program for specific services, listed on the Scope of Accreditation, for:

Asbestos Fiber Analysis

2016-07-01 through 2017-06-30Effective Dates For the National Voluntary Laboratory Accreditation Program

This laboratory is accredited in accordance with the recognized International Standard ISO/IEC 17025:2005. This accreditation demonstrates technical competence for a defined scope and the operation of a laboratory quality

management system (refer to joint ISO-ILAC-IAF Communique dated January 2009).

National Voluntary Laboratory Accreditation Program

SCOPE OF ACCREDITATION TO ISO/IEC 17025:2005

Page 1 of 1

For the National Voluntary Laboratory Accreditation Program

Effective 2016-07-01 through 2017-06-30

EMSL Analytical, Inc.464 McCormick St.

San Leandro, CA 94577Mr. Chris Dojlidko

Phone: 510-895-3675 Fax: (510) 895-3680Email: [email protected]

http://www.emsl.com

ASBESTOS FIBER ANALYSIS NVLAP LAB CODE 101048-3

Bulk Asbestos Analysis

Code Description18/A01 EPA 600/M4-82-020: Interim Method for the Determination of Asbestos in Bulk Insulation Samples

18/A03 EPA 600/R-93/116: Method for the Determination of Asbestos in Bulk Building Materials

Airborne Asbestos Analysis

Code Description18/A02 U.S. EPA's "Interim Transmission Electron Microscopy Analytical Methods-Mandatory and

Nonmandatory-and Mandatory Section to Determine Completion of Response Actions" as found in 40 CFR, Part 763, Subpart E, Appendix A.

APPENDIX B

LEAD XRF SURVEY REPORT

APPENDIX C

FIRE ALARM DRAWINGS

Quad / Student CenterSeismic / Modernization

Project

Piedmont High School800 Magnolia AvenuePiedmont, California

Piedmont Unified School District

DSA BACKCHECK08/19/2009

P:\2008\08017-Piedmont HS and MS\8017-FA-0.dwg, 8/7/2009 1:23:24 PM, DWG To PDF2.pc3


Project




SCALE: 1/8" = 1'-0"

ADMINISTRATION & CLASSROOMS FLOOR PLAN


SCALE: NO SCALE

FIRE ALARM RISER DIAGRAM BUILDING 10 (SLC #1, NAC #1)

SCALE: NO SCALE

FIRE ALARM RISER DIAGRAM BUILDING 20 (SLC #1, NAC #1)

SHEET NOTES:

NOTE:


Project





markm

Rectangle

SCALE: NO SCALE FIRE ALARM RISER DIAGRAM BUILDING 20 (SLC #1, NAC #1) NOTE:

APPENDIX D

PHOTO LOG

Photo Log Job No. 1048

Photo Log Page - 1

Photo #1 Adminstration Building Entrance

View looking north Note white pebble texture coat on wall.


Photo Log Page - 2

Photo #2

Adminstration Building Entrance View looking north

Note white pebble texture coat on column.


Photo Log Page - 3

Photo #3 Adminstration Building Roof

View looking south west TWW Portico visible


Photo Log Page - 4

Photo #4 Adminstration Building Roof

View looking north east TWW Sunshade visible


Photo Log Page - 5

Photo #5

Adminstration Building Roof View looking north west

HVAC unit and TWW equipment surroung visible


Photo Log Page - 6

Photo #6

Adminstration Building Interior Work Room

Interior View of Work Room with Sink with ACM soundproof coating


Photo Log Page - 7

Photo #7

Adminstration Building Interior Interior Column

Note: white pebble texture coat.

APPENDIX E

REGULATORY INFORMATION/NOTIFICATION FORMS

DEMOLITION REGULATION 11, Rule 2

Notification Form

Site of Demolition

For Office Use Only J# I#

Site Address: Cross Street: City: Zip: Owner/Operator Phone ( ) Specific Location of Project within Building/Address: Check One: Single Family Dwelling Commercial Multifamily Dwelling Govt Bldg School

Contractor/Individual Performing Demolition

Name: Company/Individual Contact: Mailing Address: City: Zip: Phone: ( )

Have you previously submitted notifications for other sites? Yes No

Description of Demolition

Is this Demolition by Fire for Fire Training purposes? yes No

Is this Demolition ordered by a Government Agency? yes No (Emergency only – attach copy of order) If not Demolition for Fire Training, check applicable method: Heavy Equipment Implosion By Hand Other Dates of Demolition: (Actual dates must be entered, "ASAP" or "SOON" will be rejected.) Start: Completion: Weekend Work? Night Work (After 5 PM)?

Asbestos Survey Report

Name of company that conducted survey: Address:

City: Zip: Phone: ( ) Name of person who completed the survey: CAC/SST #: Is /was asbestos present? Yes No If yes, who will remove/has removed prior to demo?

Form Preparation Information

This form prepared by: Title: Name: Company/Individual Phone: ( ) Address: City: State: Zip:

See Page Two to Complete This Form www.baaqmd.gov

Required Information

Payment must be received before J# will be assigned. See Schedule L of Regulation 3 for appropriate fees. Payment type: Check Cashier’s Check Money Order Credit/ Debit Card* (American Express, Discover, Visa, MasterCard or Debit Card) (payments, other than credit card payment, must be mailed or delivered to: 939 Ellis St., San Francisco, CA 94109)

I certify that the above information is correct and that I will comply with all of the requirements of the BAAQMD's regulations, as well as all other applicable federal, state and local requirements. Signature of Contractor or Person Performing Demolition:

Form: 1102_demolition_061615 GENERAL INFORMATION ♦ This notification form shall be used to notify the BAAQMD of a demolition operation only. Notification is

required for every demolition. All boxes must be completed. Notifications may be faxed to (415) 749-4658. *To make credit or debit card payment, go to www.baaqmd.gov/payments to pay on-line. Credit card forms will no longer be accepted. Job numbers will not be issued until applicable fees are received.

♦ Notification shall be provided to the District at least 10 working days prior to commencement of demolition, or as early as possible prior to commencement of emergency demolition. The notification period will not start until a complete notification is submitted (see above).

♦ An Acknowledgement Letter is mailed to the contractor/person listed within 3-5 days of receipt of a complete notification. This should be checked for accuracy of data.

♦ If the job is postponed or cancelled, the District must be notified of a revision; the Acknowledgement Letter should be used to fax or mail the revision information. When cancelled, a cancellation fee will apply.

♦ For specifically-defined "Emergency" conditions, the 10 working day period will be waived. Notification must be made by fax, and the job number will be issued if accompanied with a faxed copy of a valid check, cashier’s check or money order.

♦ For 4 or fewer unit residences, the 10 working day period may be reduced to 72 hours for an additional fee. INSTRUCTIONS ♦ SPECIFIC LOCATION OF PROJECT: Identify where the demolition is taking place if the site contains more

than one building. ♦ START AND COMPLETION DATES: The start date is the date on which demolition of the facility or

structure commences. Any revision to the start or completion dates must be submitted prior to the previously notified date(s). Under no circumstances may the revised start date be earlier than the 10th working day following the postmark or fax date of the original notification. If the start date is unknown, enter an estimated start date and revise the notification when the actual start date is known, but not later than the estimated start date.

♦ FIRE TRAINING: Reg. 11-2-206 includes "intentional burning" in the definition of demolition. Notification is required, the 10 working day requirement must be met and all Asbestos-Containing Material (ACM) >1% must be removed prior to fire training. The District's Open Burning Notification form must also be filed and the applicable requirements of Regulation 5 must be met.

♦ SURVEY REPORT: Provide information showing that prior to commencement of the demolition, a survey was performed to determine the presence of Regulated ACM (RACM). Indicate if there was/was not suspected ACM.

♦ GOVERNMENT ORDERED DEMOLITION: If an "Emergency" demolition (see above) is the result of a state or local agency declaring the building a public nuisance or structurally unsound and in danger of imminent collapse, a copy of the written order must accompany this notification.

939 Ellis Street San Francisco, California 94109 (415) 749-4762

http://www.baaqmd.gov/payments

FEES APPLICABLE TO DEMOLITION OPERATIONS (FROM REGULATION 3, SCHEDULE L) Demolition conducted at a single family dwelling is subject to the following fee:

OPERATION FEE: $88 Cancellation: $88 (100% of fee) non-refundable, for notification processing.

Demolition conducted at a single family dwelling or multiple family dwelling with four or fewer units with 72 hours instead of 10 days prior notice (excluding emergencies) is allowed upon payment of the following additional fee:

OPERATION FEE: $606 Demolition, other than those conducted at a single family dwelling, is subject to the following fee:

OPERATION FEE: $364 Cancellation: $243 of above amount non-refundable for notification processing.

Demolition conducted for the purpose of fire training is exempt from fee. SURVEY REQUIREMENTS FOR DEMOLITION OPERATION (FROM REGULATION 11, RULE 2) 303.8 Surveys: Except for ordered demolitions, prior to commencement of any demolition or renovation, the owner or operator shall thoroughly survey the affected structure or portion thereof for the presence of asbestos-containing material, including Category I and Category II nonfriable asbestos-containing material. The survey shall be performed by a person who is certified by the Division of Occupational Safety and Health, and who has taken and passed an EPA-approved Building Inspector course and who conforms to the procedures outlined in the course. The survey shall include sampling and the results of laboratory analysis of the asbestos content of all suspected asbestos-containing materials. This survey shall be made available, upon request by the APCO, prior to the commencement of any RACM removal or any demolition. This subsection shall not apply if the owner or operator asserts that the material to be renovated is RACM and will be handled in accordance with the provisions of Sections 11-2-303, 304 and 401. The requirement for certification by the Division of Occupational Safety and Health shall not apply to in-house health professionals within a specific nonasbestos related company who perform occasional surveys only for that company as part of their regular job responsibilities 8.1 When a structure, or portion thereof, is demolished under an ordered demolition, the survey must be done prior to, during, or after the demolition but prior to loading or removal of any demolition debris. If the debris contains regulated asbestos-containing material, all of the debris shall be treated as asbestos-containing waste material pursuant to Section 11-2-304. 8.2 For renovation or demolition of residential buildings having four or fewer dwelling units, a survey is not required. A sample and test of the material will be required only when any of the following will be removed or disturbed: heating, ventilation, air conditioning ducting and systems; acoustic ceiling material or acoustic plaster; textured or skim coated wall surfaces, cement siding or stucco, or resilient flooring. Where the material is found to contain greater than 1 percent asbestos and is friable, the material must be handled in accordance with Section 11-2-303. 6/2015

STATE OF CALIFORNIA

DEPARTMENT OF INDUSTRIAL RELATIONS DIVISION OF OCCUPATIONAL SAFETY AND HEALTH

CAL/OSHA Form 183B Rev 04/2004

Temporary Worksite Notification for Asbestos-Related Work

Company/Employer Name: ___________________________________________ ________________________________________________________________

Headquarters Address: _________________________________________________

_______________________________________________________________________

Contractors State License Board License Number: ______________________________

DOSH-ACRU (Cal/OSHA) Asbestos Registration Number: ______________________

And/or “Report of Use” Registry number: _________________________

Address of Temporary Worksite and Precise Location: ___________________________

_______________________________________________________________________

Nearest intersection: ______________________________________________________

Type of Business: _________________________________________________________

*Name of Certified Supervisor: ______________________________________________

________________________________________________________________________

________________________________________________________________________

*Name of Qualified person in charge of air

monitoring,

laboratory work, and respirators: _____________________________________________

*Name of Certified of Consultant: ____________________________________________

Projected job starting date: _____________projected completion date: _______________

Describe type, scope and work practices of job: _________________________________

________________________________________________________________________

________________________________________________________________________

Evaluation of potential for exposure: __________________________________________

________________________________________________________________________

Estimated number of employees on this job: ____________________________________

Prior to the start of each job or phase of asbestos-related work requiring the

employer or contractor to be registered, Section 341.9 of the California Code of

Regulations (8 CCR 341.9) requires notifications to the nearest DOSH District

Office. Do not send this notification to DOSH Headquarters or to DOSH Consultation.

This will not satisfy the notification requirement and could result in citation.

Note: Any change in the information provided to the district office by the written notice

shall be reported to the district office within 24 hours of such change.

STATE OF CALIFORNIA LEAD-WORK PRE-JOB NOTIFICATIONDivision of Occupational Safety and Health

*Name of employer doing 'Lead Work' *Address *Zipcode *Phone

Pager/cellular phone no.Calif. Cont. Lic. No. (if applicable)

* Supervisor name:

California Department of Health Services Lead Cert. No.

*Job start date/time *Job completion date/time Shift (Check all that apply) *Approximate duration of 'Lead Work' in days

*Street address or location of job

Entity contracting the lead-work (check one) Zipcode

Pager/cellular phone no.

Type of structure and use: (Check all that apply)

Torch cutting/weldingDuration of work:

Concentration of lead in disturbed materials:

_____________________ parts per million (ppm) _____________________ % percent by weight

_____________________ mg/cm2Assumed to be lead-containing:

Name of Notifier: Title: Date:

*Precise location of work (building no., room no., etc.)

Other work practices disturbing lead:

*Describe paint removal methods (Check all that apply):

City

County

(if applicable)

Nearest cross street

Zipcode

Address

*Describe lead-related work to be done (check all that apply)

(*Note: items marked are required)

*Amount of area to be disturbed: (Check one per column)

*Number of lead-job workers: (Check one below)Supervisor:

Scope of work and work practices:

Phone

Annual Notification for Steel Structures

1 - 5

6 - 10

11 - 20

21 - 30

31 - 40

41 - 50

> 50

Day

Swing

Graveyard

Other

Premises Owner Lessee

Office Building

Public Access/Commercial

Residence

School

Steel Structure/Type

Other

OtherSurface Preparation

Window/Door Repair/Replacement

Water/Moisture Damage Repair

Wall Repair

Demolition

Paint Removal

Manual Scraping/Sanding

Chemical Stripping

Power Sanding/Grinding

Demolition

Abrasive Blasting

Heat Guns

Hydroblasting

Welding

Torch Cutting

< 10 square feet

10 - 100 square feet

> 1000 square feet

101 - 1000 square feet

< 10 linear feet

10 - 100 linear feet

100 - 1000 linear feet

> 1000 linear feet

YES

This information is provided in accordance with Title 8, California Code of Regulations, Construction Safety OrderSection1532.1 (p). 1/25/02

Name:

Revised on 3/14/2011

CITY OF PIEDMONT, DEPARTMENT OF PUBLIC WORKS 120 VISTA AVENUE, PIEDMONT, CA 94611

TEL: (510) 420-3050 FAX: (510) 658-3167

Construction & Demolition Debris Recycling Statement (DRS) Complete this form for all construction, demolition and/or renovation projects with a valuation of $50,000 or more. Please note that building permits will not be issued without a completed and signed DRS. A separate DRS is required for each building permit. Submit the DRS with your building permit application. Prior to the start of construction/demolition, submit a completed Drop Box/Dumpster Application. Please call (510) 420-3050 or visit the City’s website for additional information. Project Address: Building Permit No.:

Owner Name: ____________________________________

Address: ________________________________________

_______________________________________________

Phone: __________________ Fax: ___________________

Contractor Name: _________________________________

Address: ________________________________________

________________________________________________

Phone: ___________________ Fax: __________________

Project Valuation $ Project Type: Demolition Construction

Project Description:

Exclusive debris hauling by Franchised Hauler. The City Council has authorized a single franchised waste hauler, Richmond Sanitary Service, to provide debris boxes within the City limits. Contractors, or any other paid hauler other than Richmond Sanitary Service, may not remove debris for homeowners. Do not place non-recyclable material in the C&D recycling drop box! Please note that if the drop box intended for the collection of mixed recyclable debris is contaminated with debris that is not recyclable, the contents of the box will be treated as waste (non-recyclable material) and taken to the landfill. As a result, you may fail to meet the requirements of the C&D Ordinance. Verification of Compliance. Verification by Richmond Sanitary Service that the debris box was used exclusively for the purpose of collecting only materials on the List of Eligible Materials for C&D Recycling is required. When the project is completed and prior to final inspection, the Applicant shall submit collection receipt(s) from Republic Services to the Department of Public Works. Applicants that have salvaged or reused debris in order to comply with the 50% diversion goal are required to submit a Salvaged Materials Form (SMF).

I believe it is infeasible to recycle, reuse or salvage at least 50% of the debris generated by my project and would like to apply for an Infeasibility Exemption. I have attached a detailed letter that estimates the amount of debris from my project and states the reason(s) that I believe make my project uniquely unable to comply. My letter includes the project’s maximum feasible diversion rate, a list of each material the project will generate and the material’s estimated weight, and the maximum rate of diversion for that material.

The City of Piedmont C&D Recycling Ordinance requires at least 50% diversion from the landfill of job-site waste materials. I understand that I am bound to comply with the requirements of this Ordinance and will present all required documents related to this project for review. I further understand that if I do not meet the requirements of this ordinance, I could be subject to penalties as listed in Article II of Chapter 1 of the Piedmont Municipal Code. Applicant’s Signature Date Office Use Only DRS: Approved Denied Exemption: Approved Denied

Building Official: _________________________________________________ Date: ____________________________

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CITY OF PIEDMONT, DEPARTMENT OF PUBLIC WORKS 120 VISTA AVENUE, PIEDMONT, CA 94611 TEL: (510) 420-3050 FAX: (510) 658-3167

Construction & Demolition Debris Salvaged Materials Form (SMF)

Project Address: Building Permit No.:

Owner Name: ____________________________________

Address: ________________________________________

________________________________________________

Phone: ________________ Fax: _____________________

Contractor Name: _________________________________

Address: ________________________________________

________________________________________________

Phone: ________________ Fax: _____________________

Project Valuation $ Project Type: � Demolition �Construction

Project Description:

Deconstruction. Applicants for projects involving the removal of all or part of an existing structure shall consider deconstruction to the maximum extent feasible, and shall make the materials generated thereby available for salvage. Prior to the issuance of a Final Inspection Permit, the Applicant shall submit a Salvaged Materials Form that itemizes the materials salvaged, with an estimate of the weight and number of items, accompanied with receipts and/or weight tags from the salvage operation. Documentation of Salvaged Materials. Applicants shall make reasonable efforts to ensure that all materials salvaged are measured and recorded using the most accurate method of measurement available. To the extent practical, salvaged materials shall either be weighed by measurement on scales in compliance with all regulatory requirements for accuracy and maintenance, or for salvaged material for which weighing is not practical due to small size or other considerations, a volumetric measurement shall be used. For conversion of volumetric measurements to weight, the Applicant shall use the standardized Conversion Rates approved by the City for this purpose (See the attached Salvaged Materials Conversion Table). For salvaged materials or items that were donated or sold for reuse, an itemized list of such items specifying the weight, size and number of items shall be provided prior to the Final Building Permit Inspection, accompanied by receipts from the charitable organization or salvage operation receiving the items. Materials that can be salvaged or reused include:

wood beams, joists, studs, baseboards cabinets and cupboards railings brick doors and casings

windows bathroom fixtures light fixtures furnishings replantable trees, shrubs

Salvaged Items Weight in Tons1 Facility/Service Provider used2 1 Please refer to the attached Salvaged Materials Conversion Table 2 For assistance in salvaging materials at the jobsite, refer to the Builders’ Guide to Reuse and Recycling.

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TABLE OF TYPICAL MATERIALS GENERATED BY RESIDENTIAL CONSTRUCTION PROJECTS

MATERIAL YES NO SAL.

Aluminum – painted or unpainted, including windows √ Asphalt √ Bricks, crushed √ Bricks, whole √ Cardboard √ Carpeting √ Cinder Blocks √ Concrete √ Copper, unpainted and painted √ Dirt, clean fill w/ no rocks or concrete √ Drywall (unpainted) √ Drywall (painted) √ Electrical Wire √ Fiberglass √ Formica √ Glass √ Granite, fireplace surrounds, counters, floors √ √ Iron, painted, unpainted, wrought and cast √ Lead √ Linoleum √ Marble – fireplace surrounds, counters, floors √ √ Plaster √ Plant Debris √ Plastics √ Pressboard √ Porcelain – tubs, toilets, sinks √ Roofs – composition shingle, tar and gravel, cap sheet, synthetic √ Roofs – shake, shingle, concrete tile and clay tile √ Steel, including windows √ √ Stucco, separated from wire √ Tile – ceramic √ Tile - concrete √ Vinyl – windows, floors √ Windows √ Wood, unpainted, including lath w/ no plaster, shingles, shakes √ Wood, painted, stained or treated √

Key: Yes = material can be recycled currently by Richmond Sanitary Service or used as alternative daily cover No = the material is solid waste that will end up in the landfill Sal = Salvage material that may be resold through a salvage company

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Construction & Demolition Debris Waste Reduction and Recycling Plan (WRRP) This form must be completed for construction and demolition projects with construction valuation exceeding $50,000 and that have been approved to NOT use the hauling and disposal services of the City’s franchised waste hauler, Richmond Sanitary Service.

Building permits will not be issued without an approved WRRP. Separate WRRPs are required for each building permit. Submit with a building permit application to the Public Works Counter, City Hall, 120 Vista Avenue, Piedmont, CA 94611. Please read instructions carefully. Incomplete forms will be returned to applicant and may delay issuance of permit.

If you have questions, call (510) 420-3050. DO NOT ATTACH ADDITIONAL ITEMS.

1) Project Type (check one): New Construction Addition/Alteration Demolition 2) Size of Project ________________ sq. ft Project Valuation $___________________ 3) Estimated Start Date____/_____/_____ Estimated Completion Date___/____/____ 4) a. Briefly describe project (e.g. remodel kitchen, construct rear deck, etc.)____________________

__________________________________________________________________________________________________________________________________________________________________________________________________ b. How will scrap or waste materials be handled to ensure salvage, reuse or recycling? __________ __________________________________________________________________________________________________________________________________________________________________________________________________ c. How will employees and subcontractors know of recycling plan and goals? ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Building Permit Application #: Property Owner:

Project Address: _______________________________________________

Contact Name: __________________________________ Title: _____________________________

Company: _________________________________________________________________________

Contact Mailing Address: ____________________________________________________________

City________________________________________ State____________________ ZIP__________

Phone: _________________ Fax: __________________ Email: ____________________________

For City Use Only: Permit No.___________________ App Filed ____/____/____ WRRP Submitted____/____/____

DR App. No. ________________ Received by ________

WRRP Approved____/____/____ By Conditions?

� 50% Diversion �Good Faith Effort �Approved �Conditional Approval � Not Approved

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REQUIREMENT: Recycle at least 50% of all construction and demolition debris (tons).

Instructions: Develop a plan outlining how much scrap and debris will be generated during construction or demolition and include handling methods for all materials. Complete the chart below and make sure your column totals are correct. The Builders Guide to Reuse & Recycling lists vendors and recycling centers.

Column A – Tons of scrap or debris for each material type. Refer to your materials take-offs. Use Materials Conversion Worksheet to convert from cy, sqft, bdft, etc. to tons Columns B, C, D – quantities to be salvaged or reused; recycled; or disposed. See worksheet for definitions. Column E –list vendors or facilities you plan to use for salvage or reuse, recycle, or disposal. Column Totals – Add up all quantities listed in Column A, B, C and D.

Material Type A B C D E (circle all that apply) Total TONS

Discarded Salvage or

Reuse* Recycling* Disposal* Proposed Destination(s) from

Builder's Guide

Asphalt/Concrete

do not add to total tonnage

Brick, Masonry, Tile Cabinets, Fixtures, Doors, Windows, Equipment

Carpet Carpet Padding Cardboard Ceiling Tile (acoustic) Drywall6 Drywall (unpainted new scrap or sheets)

Landscape Debris (brush, chips, trees, stumps, etc.)

Scrap Metal (all types) Wood, Pallets, & Lumber (clean & unpainted, no pressure treated wood)

Non-Recyclable Debris (indicate)

Other (indicate) Recyclable Mixed Debris §

* See instructions for definition of Salvage/Reuse

§ See instructions for Mixed Debris, Rebate Program and preferential pricing information.

7. Fill in the blanks below to calculate your recycling rate.

Column Totals B ___ + C ___ = ____ ÷ A ____ = _____x 100 = _____% 8. Is the percentage listed in #7 greater than or equal to 50%? � YES � NO If NO, explain why ____________________________________________________________________________________ ____________________________________________________________________________________________________

Print Name: ________________________ Signature:__________________________ Date___/___/____

City of Piedmont DROP BOX – DUMPSTER APPLICATION

C&D Debris Recycling Mandatory

If yes, a DRS is required to be submitted with building permit application. Project Address:

Property Owner:

Owner Address: Phone:

Dates Requested: From To

Location:

Reason for Drop Box: Construction Project -- Building Permit #

Other

Type of Drop Box: Mixed Recyclables Separated Recyclables

Green Recyclables Solid Waste (Trash)

APPLICANT (if other than above):

Name:

Company:

Address:

Business Phone: Cell Phone:

SPECIAL CONDITIONS: 1. Must maintain a minimum of 20 foot egress for emergency apparatus.

2. No parking signs required across street from site of dumpster.

NOTE: All dumpsters must be ordered through Richmond Sanitary Service, (800) 320-8077

OFFICE USE ONLY: $30 FEE PAID ________ Date ___________ Permit No. ________________________

Approved Denied ____________________________________ ______________

Public Works Department Date

Approved Denied ____________________________________ ______________

Fire Department Date Faxed to Richmond Sanitary: ____________________________________ ______________ Date

please see reverse

By contractual agreement between the City of Piedmont and Richmond Sanitary Services, Richmond Sanitary has an exclusive right to provide Drop Box, Debris Box, and Roll-Off Box Services to Piedmont property owners. No other hauling company may provide those services for properties within the City of Piedmont. Prices charged by Richmond Sanitary Services are regulated by the contract between the City and Richmond Sanitary. The following exceptions apply:

Solid Waste Materials: Homeowners (not their contractor, subcontractor or other agent) may personally transport solid waste materials to a licensed solid waste disposal, transfer or processing facility. Recycling Materials: Homeowners may give recyclable materials to another hauling service or a recycling processor provided that no compensation of any kind is given to either the hauler or processor for the collection or disposal of the materials.

Drop Boxes related to Construction Projects:

Drop box applications, in connection with a construction project and building permit, are valid for the duration of the project. The contractor or homeowner may swap out boxes (a full for an empty, for example) or go through periods of interrupted service.

Drop Boxes for Other Uses:

Drop box applications, when requested by homeowners for personal use (cleaning out a house or garage, for example), are for ONE box only for the dates specified on the application. Should the homeowner need another box, either during the same time period or at another date in the future, another application must be submitted to the Public Works Department.

To make arrangements to have a debris box, drop box or roll-off box delivered to your residence for the collection and removal of either solid waste or recyclable materials, please complete the drop box application at the Public Works Office and allow 24 - 48 hours before contacting Richmond Sanitary Services at 800-320-8077.

APPENDIX F*

HAZARDOUS MATERIAL SPECIFICATIONS HAZARDOUS MATERIAL ABATEMENT DRAWINGS

*Hazardous Material Specifications and Drawings will be included in a separate submittal and incorporated into the report by reference.

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